On 20 June 2019 the Department of Treasury's Office of Foreign Assets Control (OFAC) issued a final interim rule (effective on 21 June 2019) amending its reporting, procedures, and penalties regulations, 31 Code of Federal...more
7/26/2019
/ Confidential Information ,
Disclosure Requirements ,
Economic Sanctions ,
Factoring Transactions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Interim Rule ,
License Applications ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more
7/3/2019
/ Cooperative Compliance Regime ,
Economic Sanctions ,
Failure to Comply ,
Foreign Policy ,
Foreign Relations ,
Framework Agreement ,
Fund Managers ,
Internal Controls ,
Investment Funds ,
Investment Management ,
Office of Foreign Assets Control (OFAC) ,
Private Equity ,
Risk Assessment ,
Sanction Violations
On 4 June 2019 the Trump administration implemented certain regulatory changes first announced on 17 April 2019 by National Security Advisor Ambassador John Bolton in a foreign policy address regarding the Trump...more
On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more
OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US...more
On 28 January 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) for operating in the oil sector of the...more
On 19 December 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) submitted a notification to Congress that it plans to terminate sanctions on three major companies originally designated for...more
The Commerce Department is soliciting public input on identification of certain "emerging technologies" for purposes of new export controls and the recently expanded jurisdiction of the Committee on Foreign Investment in the...more
On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more
11/8/2018
/ Economic Sanctions ,
Financial Institutions ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Shipping Cargo ,
Trump Administration
The Department of the Treasury has released two new interim rules that (i) update existing regulations regarding the Committee on Foreign Investment in the United States (CFIUS) pursuant to the Foreign Investment Risk Review...more
The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more
After nearly 20 years of promulgation by executive orders, bipartisan export control reform legislation has re-established a permanent statutory basis for the control of commercial and dual-use items licensed by the...more
The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more
8/13/2018
/ Economic Sanctions ,
Energy Sector ,
Financial Institutions ,
Foreign Investment ,
Foreign Policy ,
Foreign Relations ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
ITSR ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping
On 8 August, the U.S. Department of State announced that new sanctions would be imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). The sanctions relate to...more
The Foreign Investment Risk Review Modernization Act (FIRRMA), included in the reconciled Conference Report of the FY19 National Defense Authorization Act, substantially expands the jurisdiction of the Committee on Foreign...more
8/6/2018
/ Acquisitions ,
Amended Rules ,
Carve Out Provisions ,
CFIUS ,
Covered Transactions ,
Defense Production Act ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Hedge Funds ,
Investment Funds ,
Mergers ,
National Security ,
National Security Review Proceedings ,
NDAA ,
Private Equity ,
Venture Capital
Congress has moved closer to expanding the jurisdiction and powers of the Committee on Foreign Investment in the United States (CFIUS), the U.S. interagency committee that conducts national security reviews of foreign...more
8/2/2018
/ CFIUS ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Controls ,
Financial Regulatory Reform ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Legislative Agendas ,
National Security ,
Passive Activity ,
Pending Legislation ,
Trump Administration
In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more
Driven by concerns of China’s acquisition of advanced U.S. technologies, the U.S. Congress is set to enact the most significant reform to the Committee on Foreign Investment in the United States (CFIUS) in over a decade....more
6/29/2018
/ CFIUS ,
China ,
Covered Transactions ,
Emerging Technology Companies ,
FIRRMA ,
Foreign Investment ,
Legislative Agendas ,
National Security ,
Passive Investments ,
Pending Legislation ,
Trump Administration
On 15 June 2018 the United States Trade Representative (USTR) announced the imposition of additional 25 percent tariffs (i.e., a 25 percent tax) on US$34 billion in annual imports from China. The new duties will be effective...more
Currently the UK, as a Member State of the EU, adopts UK and EU sanctions through EU Council decisions and regulations, brought into effect in the UK by Section 2 of the European Communities Act 1972....more
Declaring that it is “defective at its core,” on 8 May 2018, President Trump announced that the United States would withdraw from the Iran nuclear deal and begin re-imposing sanctions that were lifted pursuant to U.S....more
Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more
As potential trade war looms, nearly 1,300 U.S.-imports may be subject to additional 25 percent tariffs under Section 301.
U.S. imports from China potentially subject to additional duties include certain chemicals,...more
4/9/2018
/ Aluminum Sales ,
China ,
Foreign Relations ,
Global Market ,
Imports ,
National Security ,
Steel Industry ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR
Virtually all industries are being reshaped with the use of Artificial Intelligence and advanced machine-learning.
Everything from healthtech to self-driving vehicles, to education and smart homes, drones and space, social...more
4/4/2018
/ Antitrust Provisions ,
Artificial Intelligence ,
Asia Pacific ,
Connected Cars ,
Connected Items ,
Drones ,
Ethics ,
Export Controls ,
FinTech ,
Intellectual Property Protection ,
Life Sciences ,
Outer Space ,
Popular ,
Regulatory Oversight ,
Robotics ,
Satellites ,
Smart Devices ,
Unmanned Aircraft Systems
Read our Spring 2018 issue of the Immigration newsletter to learn about the following topics:
- Visa sanctions on Cambodia, Eritrea, Guinea, and Sierra Leone
- CBP introduces policies and procedures for searching...more
4/3/2018
/ Customs and Border Protection ,
Employment Eligibility Verification ,
Form I-9 ,
H-1B ,
I-485 Applications ,
Immigrants ,
Immigration Procedures ,
Immigration Reform ,
International Travel ,
Legislative Agendas ,
Mobile Devices ,
Proposed Legislation ,
Quotas ,
Search & Seizure ,
TN-Visas ,
Trump Administration ,
Visas