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OFAC Signals Policy Change on Holding Conferences with Sanctioned Speakers

Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more

Fifth Circuit Rejects OFAC’s Tornado Cash Sanctions

In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more

New Act Authorizes Sanctions for Trade Secret Theft

Congress recently passed and sent to the president the Protecting American Intellectual Property Act of 2022. The act mandates sanctions on entities and individuals identified by the executive branch as having committed...more

OFAC Issues Updated Advisory on Sanctions Risks for Facilitating Ransomware Payments

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more

OFAC Publishes Hong Kong Sanctions Regulations: Implications for Business With Hong Kong Entities

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published final rules on January 15, 2021, implementing the sanctions put in place by Executive Order 13936 (EO 13936) and the Hong Kong Autonomy Act...more

Implications of the New Executive Order Prohibiting Transactions in Publicly Traded Securities of Chinese Military Companies

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

Implications for Chinese Investment in the US After Section 301 Report

Section 301 provides the president with broad authority to implement new policies and procedures that could impact reviews of Chinese investment in the United States. The president could rely on the International Emergency...more

Federal Criminal Case Raises Provocative Questions on US Jurisdiction

Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more

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