The FCC recently reminded television broadcasters and multichannel video program distributors (MVPDs) of the importance of providing accessible televised emergency information amid concerns regarding the COVID-19 pandemic....more
By March 30, 2020 (postponed from January 30), all commercial full power and Class A TV stations must prepare and file their initial annual Children's Programming Report and post online documentation demonstrating compliance...more
In its recent Report and Order (Order), the Federal Communication Commission (FCC) adopted a rule prohibiting the use of Universal Service Fund (USF) funds by USF recipients that are eligible telecommunications carriers...more
Department of Treasury Issues Final FIRRMA Regulations -
The U.S. Treasury Department has issued final rules (the Regulations) implementing changes to the foreign investment review process administered by the Committee on...more
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) on January 6, 2020, requiring a license for the export of certain "Geospatial Imagery" software technology to all...more
The U.S. Department of Commerce today published a proposed rule to implement Executive Order 13873, Securing the Information and Communications Technology and Services (ICTS) Supply Chain. ...more
On the eve of a new round of U.S.-China trade talks in Washington on October 10, the U.S. Department of Commerce has added eight major Chinese technology firms – all deeply rooted in the surveillance and artificial...more
On September 17, 2019, the Department of the Treasury issued two Proposed Rules intended to implement changes made by the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) to the Defense Production Act of 1950...more
The September 30 deadline is fast approaching for submitting the Annual Report of Blocked Property (ARBP) to the U.S. Department of Treasury Office of Foreign Assets Control (OFAC). ...more
As mandated by Section 889 (a) (1) (A) of the 2019 National Defense Authorization Act ("NDAA"), the Defense Department, General Services Agency and NASA have issued the pre-publication version of an interim rule that bars...more
In apparent recognition of the chaos that its recent inclusion of Huawei Technologies Co., Ltd. and 68 non-U.S. affiliates (collectively, “Huawei”) on the Department of Commerce’s (DOC) Entity List could cause, on May 20,...more
On May 15, 2019, in a one-two punch, the White House and the U.S. Department of Commerce (DOC) took actions that effectively could ban Huawei Technologies Co. Ltd., 68 of its non-U.S. affiliates, and other unnamed Chinese...more
2018 brought with it President Trump’s decision that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”). That signaled the U.S.’s intention not only to reimpose trade sanctions on Iran but...more
As part of the 2019 National Defense Authorization Act (“2019 NDAA”), Congress recently enacted significant changes to the process by which the Committee on Foreign Investment in the United States (“CFIUS”) operates as well...more
As part of the National Defense Authorization Act (“NDAA”) for Fiscal Year 2019, Public Law No: 115-232, Congress enacted the Export Controls Act of 2018 (“ECA”)....more
9/27/2018
/ Bureau of Industry and Security (BIS) ,
CFIUS ,
China ,
Commerce Control List ,
Emerging Technology Companies ,
Export Administration Regulations (EAR) ,
Export Control Reform (ECR) ,
Export Controls ,
FIRRMA ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
NDAA ,
U.S. Commerce Department
The BE-120 Benchmark Survey of Transactions in Selected Services and Intellectual Property with Foreign Persons is conducted every five years by the Bureau of Economic Analysis of the U.S. Department of Commerce....more
The Department of Commerce’s Bureau of Economic Analysis (BEA) requires each U.S. business enterprise in which a foreign person owned or controlled, directly or indirectly, 10 percent or more of the voting securities in an...more
Addressing the issue of when “a bare procedural violation of a statutory right constitute[s] an injury in fact sufficient for standing to bring suit in federal court”, the U.S. Court of Appeals for the Second Circuit has...more
Three senators – Senate Banking Committee Ranking Member Sherrod Brown, Sen. Ron Wyden, ranking member on the Senate Finance Committee, and Sen. Claire McCaskill, ranking member on the Homeland Security and Government Affairs...more
Parties to acquisitions often find themselves in the position of the McCallisters in "Home Alone," dashing out of the house and arriving in Paris only to discover that they’ve left little Macaulay Culkin (aka Kevin) behind....more
Two related enforcement actions by the U.S. Department of Treasury’s Office of Foreign Assets Compliance (OFAC) are stark reminders that health insurance providers (and other insurers) must maintain adequate U.S. trade...more
The U.S. Department of Commerce Bureau of Industry and Security (BIS) today announced that it has extended for a period of two months a previously granted temporary reprieve from U.S. export sanctions on China’s ZTE...more
A recent enforcement action by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) against MasterCard International Incorporated (“MasterCard”) stands as a reminder of the importance of strictly...more
The U.S. Department of Commerce’s Office of Foreign Assets Control (OFAC) announced that Navigators Insurance Company, which is headquartered in New York and specializes in marine insurance and related lines of business,...more
8/10/2015
/ Compliance ,
Cuba ,
Insurance Industry ,
Iran ,
Iran Sanctions ,
Liability Insurance ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Professional Liability ,
Sanctions ,
Sudan ,
Umbrella Policies ,
Vessels
On Dec. 19, 2014, President Obama issued Executive Order 13685, “Blocking Property of Certain Persons and Prohibiting Certain Transactions With Respect to the Crimea Region of Ukraine,” to impose sanctions relating to the...more
8/6/2015
/ Banking Sector ,
Banks ,
Crimea ,
Executive Orders ,
Financial Institutions ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SWIFT ,
Trade Policy ,
U.S. Treasury ,
Ukraine