China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more
4/14/2025
/ China ,
Economic Sanctions ,
Enforcement Actions ,
Exports ,
Foreign Policy ,
Foreign Relations ,
International Trade ,
Multinationals ,
National Security ,
Regulatory Requirements ,
Trade Relations
The Situation: After President Trump issued an Executive Order ("EO") that creates a process to designate international cartels and other organizations as "Foreign Terrorist Organizations" ("FTOs") or "Specially Designated...more
3/3/2025
/ Anti-Money Laundering ,
Cartels ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Services Industry ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury
On April 11, 2024, the Treasury Department announced a prepublication copy of a proposed rule amending the regulations of the Committee on Foreign Investment in the United States ("CFIUS") (the "Proposed Rule")....more
The Committee on Foreign Investment in the United States ("CFIUS") has released its first-ever enforcement and penalty guidelines—putting industry on notice and inviting self-disclosures....more
On December 23, 2021, President Biden signed the Uyghur Forced Labor Prevention Act ("UFLPA" or the "Act") into law. The Act creates a rebuttable presumption that "any goods, wares, articles, and merchandise mined, produced,...more
4/28/2022
/ China ,
Customs and Border Protection ,
Enforcement Actions ,
Forced Labor ,
Human Rights ,
Importers ,
Imports ,
Rebuttable Presumptions ,
Supply Chain ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
The risk of detention or seizure of products imported into the United States warrants renewed attention to responsible business practices on forced labor risk in global supply chains.
United States Customs and Border...more
The Situation: The United States federal government—including Congress, the Department of Labor, the Department of Homeland Security, and the Department of the Treasury—continues to ramp up efforts to address reports of...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
1/13/2020
/ Cooperation ,
Corporate Counsel ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Non-Prosecution Agreements ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes
The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more