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China Boosts Enforcement of Anti-Foreign Sanctions Law

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

Mitigating Risk From the Designation of Cartels as FTOs and SDGTs

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

CFIUS Signals Enhanced Enforcement Focus With New Proposed Changes to Regulations

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

CFIUS Releases First-Ever Penalty and Enforcement Guidelines

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

CBP Announces Known Importer Letters Related to Uyghur Forced Labor Prevention Act

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

Sanctions Enforcement Action Provides Incentives for Companies and a Warning for Individuals

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

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