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OFAC Year in Review 2021 – Part 1

2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more

Sanctions Legislation Watch: What to Expect from Congress as 2021 Comes to a Close

As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more

Lessons Learned From OFAC’s 2021 Enforcement Actions So Far

As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more

U.S. Court Blocks Trump-Era Designation Of Xiaomi As A Chinese Military Company And Permits Continued Trading In Its Securities

On March 12, 2021, a U.S. district court granted a temporary injunction requested by the Hong Kong-listed, Chinese electronics giant, Xiaomi Corporation (“Xiaomi”). The injunction blocks the U.S. Department of Defense (“DoD”)...more

Trump Administration Gives Teeth To Pentagon List And Restricts U.S. Investment In Publicly Traded Securities Of Chinese Military...

Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more

Hong Kong In The Crosshairs: Secretary Of State Submits Hong Kong Autonomy Act Report To Congress, Paving Path For Secondary...

On Wednesday, October 14, 2020, the U.S. Department of State (“State”) submitted a report to the U.S. Congress, as required under section 5(a) of the Hong Kong Autonomy Act (“HKAA”), identifying foreign persons materially...more

China's "Unreliable Entity List" Will Be In A Dilemma When Multinational Companies Respond To US Sanctions And "Long-Arm...

China has recently introduced unreliable entity list ("Entity List") regulations to provide a framework for China's upcoming list of economic sanctions. As early as October 2018 and March 2020, China has implemented "blocking...more

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