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New Sanctions Against Venezuela's State-Owned Oil Company

Continued political turmoil in Venezuela has led to additional U.S. sanctions. On Jan. 25, 2019, President Donald Trump amended the various executive orders that authorize sanctions against the government of Venezuela to...more

CFIUS Issues Regulations for FIRRMA Pilot Program

On Oct. 10, 2018, the U.S. Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), issued interim regulations (the Regulations) setting forth the scope of,...more

New Sanctions Against Russia Have Unfavorable Impact on Defense Sector, with Carve-Outs Favoring Certain Aspects of the Aerospace...

On Aug. 27, 2018, the U.S. State Department published new sanctions against Russia based on the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) after determining that the government of...more

U.S. Government Warns about Sanctions Evasion Tactics; Heightens Need for Due Diligence

On July 23, 2018, a variety of U.S. government agencies, namely the Department of State, the Department of the Treasury’s Office of Foreign Assets Control ("OFAC"), and the Department of Homeland Security’s Customs and Border...more

Trump Administration Withdraws from Iran Nuclear Deal - Prepares to Reinstate Sanctions with Profound Domestic and International...

On May 8, 2018, the Trump administration announced that the United States will withdraw from the Joint Comprehensive Plan of Action (JCPOA) entered into between Iran, China, France, Germany, Russia, the United Kingdom and the...more

U.S. Sanctions Under the Trump Administration – International Trade Implications

The Trump Administration has been active on the sanctions front as a means of asserting U.S. foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late, beyond its...more

CFIUS Reform: Legislation Proposed to Strengthen National Security Reviews

A little-known but powerful U.S. government committee is gaining the attention of Congress. In November 2017, members of the U.S. House and Senate introduced companion legislation that would update the national security...more

U.S. Sanctions Developments in the Trump Administration

The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more

White House Imposes Sanctions in Response to Malicious Russian Cyber Activity

On Dec. 29, 2016, in response to the Russian government’s “aggressive harassment of U.S. officials and cyber operations aimed at the U.S. election,” President Obama issued an Executive Order Taking Additional Steps to Address...more

DOJ Publishes Guidance Encouraging Voluntary Self-Disclosures, Full Cooperation and Timely and Appropriate Remediation

On Oct. 2, 2016, the U.S. Department of Justice (DOJ), National Security Division (NSD) published Guidance setting forth its policy of encouraging business organizations to voluntarily self-disclose criminal violations of...more

BIS and DDTC Harmonize Destination Control Statements, Make Other Clarifying Changes

On Aug. 17, 2016, as part of the President’s Export Control Reform (ECR) initiative, the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC)...more

BIS And DDTC Revise Controls on Export of Toxicological Agents and Directed Energy Weapons

On July 28, 2016, the Department of Commerce’s Bureau of Industry and Security (BIS) and the Department of State’s Directorate of Defense Trade Controls (DDTC) issued final rules implementing revisions to U.S. export controls...more

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