The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
10/20/2021
/ China ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Hong Kong ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Public Policy ,
Russia ,
U.S. Treasury ,
Venezuela ,
Virtual Currency
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
3/23/2021
/ Biden Administration ,
China ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border ,
Cuba ,
Foreign Adversaries ,
Hong Kong ,
Interim Final Rules (IFR) ,
Iran ,
Licensing Rules ,
National Security ,
North Korea ,
Russia ,
Safe Harbors ,
Supply Chain ,
Technology ,
Telecommunications ,
U.S. Commerce Department ,
Venezuela
On December 28, 2020, the Department of the Treasury Office of Foreign Assets Control (OFAC) published awaited guidance on the implementation of Executive Order (EO) 13959, “Executive Order on Addressing the Threat from...more
On August 6, 2020, President Trump issued two nearly parallel executive orders (EOs) targeting the enormously popular apps TikTok and WeChat: Executive Order on Addressing the Threat Posed by TikTok (TikTok EO), and Executive...more
The US government has established new authorities to impose sanctions in response to China’s national security law for Hong Kong, increasing the compliance risks for international banks and other companies that do business in...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
7/2/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
National Security ,
Russia ,
Technology ,
U.S. Commerce Department ,
Venezuela
On May 15, 2020, the US Department of Commerce announced a rule further targeting Chinese telecommunications company Huawei and its chip-making subsidiary HiSilicon for allegedly engaging in “stepped-up efforts to undermine”...more
Yesterday, the US Department of Commerce Bureau of Industry and Security (BIS) promulgated two new rules and issued a new proposed rule:
..A new final rule that will restrict previously permissible exports to China, Russia...more
4/30/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
National Security ,
New Rules ,
Proposed Rules ,
Russia ,
U.S. Commerce Department ,
Venezuela
On November 26, the US Department of Commerce issued a long-awaited proposed rule (Proposed Rule) implementing new restrictions designed to protect the US information and communications technology and services (ICTS) supply...more
12/3/2019
/ CFIUS ,
China ,
Comment Period ,
Executive Orders ,
Huawei ,
Information and Communication Technology (ICT) ,
National Security ,
Proposed Rules ,
Supply Chain ,
Telecommunications ,
U.S. Commerce Department
On May 15, 2019, President Trump issued an Executive Order (EO) declaring a national emergency and paving the way for a ban on the use of Huawei equipment and services in U.S. telecommunication networks. On the same day, the...more
5/17/2019
/ Bureau of Industry and Security (BIS) ,
China ,
Executive Orders ,
Exports ,
General Licenses ,
Imports ,
National Security ,
Savings Clause ,
Supply Chain ,
Telecommunications ,
Trade Relations ,
Trump Administration ,
U.S. Commerce Department ,
US Trade Policies
On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more
On Friday, May 18, the EU Commission launched the formal process to reactivate a 1996 trade defense law in response to the US withdrawal from the Joint Comprehensive Plan of Action (JCPOA) on Iran's nuclear program. Once...more
5/23/2018
/ Blocking Statutes ,
China ,
EU ,
European Commission ,
Foreign Relations ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Russia ,
Trade Relations ,
Trump Administration