Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in...more
BitMEX, a Seychelles-based centralized exchange for trading derivatives on bitcoin, ether and litecoin, and certain of its executives have been charged with a number of violations under the U.S. Commodity Exchange Act (CEA),...more
10/8/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
CFTC ,
Commodity Exchange Act (CEA) ,
Department of Justice (DOJ) ,
Digital Assets ,
Due Diligence ,
Ether ,
Futures Commission Merchants (FCMs) ,
Geo-Blocking ,
SEFs ,
Trading Platforms ,
U.S. Customs
On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China. Under 19 U.S.C. § 1307, CBP can initiate enforcement...more
On September 18, 2020, the U.S. Commerce Department published two rules defining the scope of prohibited transactions related to the mobile applications, WeChat and TikTok. The scope of prohibited transactions clarified the...more
On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current...more
The Department of Commerce (the Department) has proposed to modify its regulations under Part 351 of Title 19 to improve administration and enforcement of the antidumping duty (AD) and countervailing duty (CVD) laws....more
On August 17, 2020, the U.S. Department of Commerce Bureau of Industry and Security (BIS) made available for public inspection a final rule expanding restrictions on Huawei Technologies Co., Ltd. and its non-U.S. affiliates...more
On August 6, 2020, President Trump issued a pair of executive orders targeting China’s Tencent Holdings Ltd. (Tencent) and its mobile application WeChat and ByteDance Ltd. (ByteDance) and its mobile application TikTok. The...more
New rules and developments continue to proliferate as the U.S. government seeks to minimize supply chain threats and cybersecurity risks.
For contract awards issued after August 13, 2020, prime contractors must conduct a...more
7/16/2020
/ Compliance ,
Cybersecurity ,
Department of Defense (DOD) ,
DFARS ,
FCC ,
Huawei ,
Interim Rule ,
National Security ,
Networks ,
Supply Chain ,
Telecommunications ,
ZTE
On July 1, 2020, the United-States-Mexico-Canada Agreement (USMCA) entered into force, replacing the 26-year-old North American Free Trade Agreement (NAFTA). The U.S. government has taken several steps toward implementation...more
Since the handover of Hong Kong by the United Kingdom to China in 1997, Hong Kong has enjoyed separate treatment from the mainland by the United States, other countries and international organizations pursuant to the “one...more
On May 22, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will add 33 Chinese companies and institutions to the Entity List. The designations will prohibit the export,...more
On May 8, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) reissued its Geographic Targeting Orders (GTOs) for 12 metropolitan areas. ...more
If past crises are any guide, public outcry for accountability, media attention and vigorous enforcement is likely in the wake of the pandemic.
Corruption, fraud and money laundering are ever-present risks during the...more
The U.S. government has taken steps to allow the United States–Mexico–Canada Agreement (USMCA) to enter into force on July 1, 2020, replacing the North American Free Trade Agreement (NAFTA). On April 24, 2020, the United...more
On April 28, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) published two final rules that will eliminate the license exception for civil end users (CIV) in the People’s Republic of China, Russia,...more
On April 6, 2020, Secretary of State Mike Pompeo designated the Russian Imperial Movement (RIM), a paramilitary and white supremacist group, and several of its leaders as Specially Designated Global Terrorists (SDGTs). This...more
On April 7, 2020, the Federal Emergency Management Agency (FEMA) released for public inspection a temporary rule that prohibits the export of five types of personal protective equipment (PPE) without explicit approval by...more
On March 12, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued sanctions against a second affiliate of PJSC Rosneft Oil Company (“Rosneft”) related to its activities with Venezuela. OFAC...more
On January 10, 2020, the United States imposed additional sanctions on Iran in the wake of recent tensions between the countries and the continuing broader ‘maximum pressure’ campaign on Iran. ...more
On December 31, 2019, the U.S. District Court for the Northern District of Texas overturned a $2 million fine imposed by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) against ExxonMobil Corp., and...more
On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications...more
The U.S. Treasury Department has issued sanctions designations against Turkey’s Ministry of National Defense, Ministry of Energy and Natural Resources, and the Minsters of Defense, Energy and Interior pursuant to a new...more
On September 17, 2019, the U.S. Department of Treasury issued two new proposed rules for the Committee on Foreign Investment in the United States (CFIUS) implementing the Foreign Investment Risk Review Modernization Act...more
Federal regulators start to address some of the recent questions about digital assets such as tokens and virtual currencies, though many questions remain.
U.S. Regulators and Congress are grappling with how to manage the...more
9/12/2019
/ Anti-Money Laundering ,
Asset Tokens ,
Commodities ,
Cryptocurrency ,
Digital Assets ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Know Your Customers ,
Legislative Agendas ,
No-Action Letters ,
Regulatory Agencies ,
Regulatory Agenda ,
Securities ,
Securities and Exchange Commission (SEC) ,
Utility Tokens ,
Virtual Currency