President Donald Trump on February 21, 2025 issued a National Security Presidential Memorandum titled the America First Investment Policy to provide guidance to executive departments in their review and decision-making with...more
The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more
OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more
The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more
The US Department of Commerce’s Bureau of Industry and Security (BIS) released an interim final rule (IFR) on October 7, 2022, imposing additional export controls on certain advanced computing and semiconductor manufacturing...more
The United States, in concert with Western allies, has imposed sweeping sanctions on Russia in response to President Vladimir Putin’s action in Ukraine. In addition to a full suite of sanctions administered by the US...more
The new executive order continues the policy of prohibiting US persons’ transactions in the publicly traded securities of select Chinese companies, but expands the scope to include both Chinese companies that operate or have...more
6/9/2021
/ Biden Administration ,
China ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Instruments ,
Foreign Policy ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Prohibited Transactions ,
Securities Transactions ,
Surveillance
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
3/23/2021
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
UK ,
UK Brexit
President Trump’s Executive Order Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies (EO 13959) prohibits transactions by or on behalf of US persons in publicly traded...more
The US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule on January 15 to implement changes to, and impose new licensing obligations under, the Export Administration Regulations...more
1/28/2021
/ Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
End-Users ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
National Security ,
WMD
The new Executive Order (EO or the Order) bans transactions by US persons in publicly traded securities of companies identified as “Chinese military companies,” and includes a ban on trading in derivatives of those securities...more
11/18/2020
/ China ,
ETFs ,
Executive Orders ,
Foreign Policy ,
Foreign Relations ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Prohibited Transactions ,
Publicly-Traded Companies ,
Securities Transactions ,
Trump Administration
Mexican President Andrés Manuel López Obrador recently announced that Mexico is willing to ship gasoline to Venezuela notwithstanding the threat of US sanctions against such activity. ...more
On August 2, US President Donald Trump signed into law the Countering America’s Adversaries Through Sanctions Act, which enacts a significant expansion of US sanctions against Russia as well as new measures relating to Iran...more