Since assuming office in January 2025, the Trump administration has sought to transform the U.S.’s approach to, and regulation of, Artificial Intelligence (AI). From signing an executive order entitled “Removing Barriers to...more
On February 10, 2025, President Trump signed an Executive Order (E.O.) directing a shift in the enforcement of the Foreign Corrupt Practices Act (FCPA). The order effectively pauses new FCPA investigations and enforcement...more
2/13/2025
/ Anti-Corruption ,
China ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Trump Administration
On her first day in office, Attorney General Pamela Bondi issued a memorandum signaling a significant shift in the Department of Justice’s (DOJ) approach to Foreign Agents Registration Act (FARA) enforcement. The memorandum...more
2/10/2025
/ Biden Administration ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
Foreign Agents Registration Act (FARA) ,
Foreign Policy ,
Investigations ,
National Security ,
Proposed Rules ,
Regulatory Reform ,
Trump Administration
1. What? Tariff Rates and Legal Authority -
President Trump signed three executive orders imposing new tariffs against Canada, Mexico, and China, following through on prior campaign and post-inauguration promises. While...more
2/4/2025
/ Canada ,
China ,
Compliance ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
Mexico ,
National Security ,
Recordkeeping Requirements ,
Section 301 ,
Supply Chain ,
Tariffs
As President Trump begins his second term, the absence of tariffs among the more than 200 executive orders signed on his first day in office was a notable deviation from expectations. However, the President announced plans to...more
1/23/2025
/ Canada ,
Compliance ,
Corporate Counsel ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
International Trade ,
International Trade Commission (ITC) ,
Mexico ,
National Security ,
Section 301 ,
Tariff Act of 1930 ,
Tariffs ,
Trade Act of 1974 ,
Trade Expansion Act of 1962 ,
Trump Administration ,
US Trade Policies
Against the backdrop of increasing international competition in the artificial intelligence (AI) space, the Enhancing National Frameworks for Overseas Critical Exports Act (the ENFORCE Act) was recently introduced in the U.S....more
6/26/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
China ,
Department of Defense (DOD) ,
Department of Energy (DOE) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Machine Learning ,
National Security ,
Semiconductors ,
US State Departments
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
3/7/2024
/ Bureau of Industry and Security (BIS) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Military Conflict ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Supply Chain ,
UK ,
Ukraine
Historically, international trade regulation has swung between economic protectionism and national security concerns. Between World War II and the 2018 presidential election, the primary international trade regulatory issue...more
1/22/2024
/ Breach of Contract ,
Bureau of Industry and Security (BIS) ,
CFIUS ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Development ,
Export Administration Regulations (EAR) ,
Foreign Investment ,
Foreign Trade Regulations ,
Foreign Trade Zones ,
Inflation Reduction Act (IRA) ,
International Trade ,
ITAR ,
National Security ,
NATO ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Semiconductors ,
Settlement Agreements ,
Supply Chain ,
United States-Mexico-Canada Agreement (USMCA) ,
Voluntary Disclosure
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
7/31/2023
/ Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
False Statements ,
Foreign Agents Registration Act (FARA) ,
Incentives ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Self-Disclosure Requirements ,
Self-Reporting ,
U.S. Treasury
In a continued theme of increased enforcement of export controls, the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce released a memorandum that announced a stricter Administrative Enforcement...more
On January 14, 2021, the U.S. Department of Commerce issued an interim final rule to address national security, economic security, and public health and safety concerns related to Information and Communications Technology and...more
1/20/2021
/ CFIUS ,
China ,
Cuba ,
Executive Orders ,
Export Controls ,
Foreign Adversaries ,
Infrastructure ,
Interim Final Rules (IFR) ,
Iran Sanctions ,
National Security ,
Russia ,
US Trade Policies ,
Venezuela
On March 27, 2020, President Trump signed into law the largest spending bill in U.S. history in an effort to combat the COVID-19 pandemic. One focus of the bill is on ensuring that sufficient amounts of critical materials are...more