On September 17, 2019, the Committee on Foreign Investment in the United States (“CFIUS”) published two Proposed Rules to implement most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). CFIUS is an...more
9/19/2019
/ CFIUS ,
Critical Infrastructure Sectors ,
Cybersecurity ,
FIRRMA ,
Foreign Investment ,
Infrastructure ,
Personal Data ,
Personally Identifiable Information ,
Proposed Rules ,
Real Estate Transactions ,
Technology Sector
Tariffs To Be Effective On September 1, 2019 For Some Products And December 15, 2019 For Others; Certain Products Will Not Be Subject To Additional Tariffs; Product Exclusion Process To Be Implemented.
...more
On June 20, 2019, the Office of the U.S. Trade Representative (“USTR”) posted on its website a notice announcing an exclusion process for the tariffs imposed in September 2018 (“List 3”) pursuant to the U.S. Section 301...more
6/24/2019
/ China ,
Exclusions ,
Imports ,
Notice Requirements ,
Section 301 ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR
For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more
5/21/2019
/ Anonymization ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Blockchain ,
BSA/AML ,
CFTC ,
Cryptocurrency ,
Digital Wallets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Money Services Business ,
New Guidance ,
Peer-to-Peer ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
USTR on May 13, 2019 announced that it proposed to impose additional tariffs on products of China with an annual trade of approximately $300 billion pursuant to a Section 301 investigation commenced in August 2017 regarding...more
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
Stepping outside of SWIFT -
Since its inception more than a decade ago, cryptocurrency has been viewed as a way to supplant traditional global methods of exchanging money. Today, as virtual currencies proliferate,...more
2/19/2019
/ Corruption ,
Cryptocurrency ,
Digital Currency ,
Economic Sanctions ,
Initial Coin Offering (ICOs) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Self-Regulatory Organizations ,
SWIFT ,
Virtual Currency
This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence -
On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more
2/8/2019
/ China ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain
Tariffs on $200 billion in Chinese imports were set to rise to 25% on January 1, 2019, but will remain at 10% for 90 days pending negotiations with China on “structural changes” to U.S.-China economic relationship -
On...more
In July and August, 2018 the United States Trade Representative (USTR) identified a list of 6,031 tariff lines affecting approximately $200 billion in imports from China for potential additional tariffs of 10 percent and...more
Second Group of Products To Be Subject To Additional Tariffs As A Result Of Section 301 Process; China Immediately Responds with 25 Percent Tariffs On $16 Billion of U.S. Goods -
On June 15, 2018, the United States Trade...more
President Trump Directed USTR To Consider Increasing The Proposed Additional Duty From 10 To 25 Percent “To Encourage China To Change Its Harmful Policies” -
On August 1, 2018, U.S. Trade Representative (USTR) Robert...more
On July 15, the United States and the EU issued a joint statement that appears to delay (and possibly avoid) additional U.S. tariffs on EU automobiles and automotive parts, at least for the time being. The U.S. Department of...more
Comments Sought By August 17, 2018 On List Of Over 6,000 Potentially Affected Tariff Lines -
The U.S. Trade Representative (USTR) has announced a new list of products imported from China that it proposes would be subject...more
King & Spalding Tariff Tracker Now Available -
Requests Are Due October 9, 2018, And Any Granted Product Exclusions Would Be Effective From July 6, 2018; Tracker Identifies Products Affected By Tariff Increases Announced...more
Lessons for Sellers in Contracting with Emerging Market Buyers: The “Three R’s” to Structuring Payment Security Provisions -
The recent rebound in the international energy industry is being driven, at least in part, by a...more
6/18/2018
/ BSEE ,
Cloud Computing ,
Energy Policy ,
Energy Sector ,
Exports ,
FERC ,
Joint Comprehensive Plan of Action (JCPOA) ,
Migratory Bird Treaty Act (MBTA) ,
Natural Gas ,
Oil & Gas ,
Pipelines ,
Proposed Rules ,
Trump Administration ,
Well Drilling
United States Trade Representative Releases Final List Of Chinese Products Subject To 25 Percent Tariff -
Today, based on a review conducted by the interagency Section 301 Committee, the Office of the United States Trade...more
6/18/2018
/ Acquisitions ,
China ,
Foreign Acquisitions ,
Imports ,
Intellectual Property Protection ,
Section 301 ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies ,
USTR
On May 11, 2018, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) implemented its Final Rule on Customer Due Diligence Requirements for Financial Institutions (“Rule”) to amend the scope of...more
On May 8, 2018, President Donald Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) negotiated between the “P5+1” countries (United States, United Kingdom, France,...more
As outlined in our prior client alert, on March 22, 2018, President Trump signed a memorandum instructing his administration to take action against the “unfair and harmful acquisition of U.S. technology” by China. Part of the...more
On March 22, 2018, President Trump signed a memorandum instructing his administration to take action against the “unfair and harmful acquisition of U.S. technology” by China.
The President previously instructed United...more
3/26/2018
/ Acquisitions ,
Antitrust Provisions ,
China ,
Cybersecurity ,
Foreign Acquisitions ,
Intellectual Property Protection ,
National Security ,
Section 301 ,
Tariffs ,
Technology Sector ,
Trump Administration ,
USTR ,
WTO
De-facto blocking evidences continuing scrutiny of Chinese investments in U.S. companies in the strategic technology and financial industries.
On January 2, 2018, MoneyGram International, Inc. (NYSE:MGI (“MoneyGram”) and...more
Order sends strong signal that Washington will continue to oppose deals with Chinese acquirers involving technologies with potential military applications.
On September 13, 2017, President Trump issued an Executive Order...more
On August 24, 2017, President Trump issued Executive Order 13808 (“E.O. 13808” or the “Executive Order”) titled “Imposing Additional Sanctions With Respect to the Situation in Venezuela.” The Executive Order prohibits certain...more
The U.S. Senate passed this week a measure to codify, strengthen and expand sanctions against the Russian Federation in response to its activities in Ukraine, cyber-attacks, interference in the U.S. Presidential election, and...more