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OFAC Releases Guidance Regarding Prohibition on New Investment in Russia and Provides Further Clarifications Regarding Investments...

I. OFAC Publishes FAQs Addressing Ban on New Investment in Russia On April 6, 2022, President Biden signed Executive Order (“EO”) 14071, which prohibits all “new investment in the Russian Federation by a United States...more

Review of Sanctions and Export Controls Imposed in Response to Russia’s Invasion of Ukraine

As we had reported in our earlier client alert and 2022 Year in Preview, Russia’s invasion of Ukraine has resulted in a new wave of sanctions and export controls on Russia, including sanctions on key sectors of the Russian...more

Possible International Trade Consequences of Further Escalation of Conflict in Ukraine

For months, the Biden administration and the governments of U.S. allies around the world have raised concerns about Russian actions in the region. In the same breath, those governments have warned of massive, coordinated...more

CBP Focus on Forced Labor in Malaysia and the Seafood Industry Continues with New WRO and Findings

On Friday, January 28, 2022, U.S. Customs and Border Protection (“CBP”) issued a Withhold Release Order (“WRO”) on disposable gloves produced in Malaysia by TY Industry Holdings Sdn Bhd (“YTY Group”), including YTY Industry...more

New CBP Withhold Release Order Again Targets Forced Labor in the Seafood Industry

New CBP Withhold Release Order Again Targets Forced Labor in the Seafood Industry August 10, 2021 On August 4, 2021, U.S. Customs and Border Protection (“CBP”) released a Withhold Release Order (“WRO”) on tuna and other...more

Biden Administration Targets Chinese Solar Power Industry Over Human Rights Abuses

As predicted in our recent article in Power Magazine related to international trade risks facing the clean energy industry, the Biden administration took action against several Chinese companies involved in the solar power...more

First WRO of Biden Administration Targets Forced Labor on Chinese Fishing Fleet

On May 28, 2021, U.S. Customs and Border Protection (“CBP”) released the first Withhold-Release Order (“WRO”) of the Biden administration on seafood from Dalian Ocean Fishing Co., Ltd. (“Dalian”), a Chinese company, due to...more

Sanctions/Export Controls Trends in 2021

This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next,...more

A Review of CBP Actions on Forced Labor in 2020 and Outlook for 2021

Withhold Release Orders (“WROs”) are a key part of Customs and Border Protection’s (“CBP”) efforts to enforce the Tariff Act, which prohibits the importation of merchandise mined, produced or manufactured, wholly or in part,...more

Cross-Border Compliance Update: May 2020

Proposed Rules on CFIUS Mandatory Declarations Released: No More NAICS Codes! On May 21, 2020, the Department of the Treasury released a proposed rule that would modify the requirements for Committee on Foreign Investment...more

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