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Unpacking the U.S. Sanctions Reversal on Syria: Implications and Future Outlook

Key Takeaways: - Executive Order 14312 revokes the six executive orders that formed the foundation of the Syrian Sanctions Program, terminates the national emergency underlying those executive orders and waives and relaxes...more

DOJ’s “Bulk Sensitive Data Rule” is in Effect, and May Require Significant Compliance Obligations as Enforcement is Set to Begin

Pursuant to a newly effective U.S. Department of Justice (DOJ) regulation, the transfer and storage of certain sensitive U.S. government and personal data may be prohibited or restricted, depending on the intended recipient,...more

The U.S. Court of International Trade Struck Down President Trump’s IEEPA Tariffs – What Happens Now?

After coming into office, President Donald Trump has invoked the International Emergency Economic Powers Act (“IEEPA”) to impose a series of tariffs on imports from worldwide trading partners. The President’s numerous...more

Biden Administration Threatens Foreign Financial Institutions With Secondary Sanctions for Involvement in Certain Transactions...

On December 22, 2023, President Biden issued a new Executive Order affecting foreign financial institutions and those importing certain goods into the U.S. In addition, OFAC provided related new and revised FAQs, as well...more

Reverse CFIUS is Coming: President Biden Issues Executive Order Addressing Certain Outbound Investments by U.S. Persons

On August 9, 2023, President Biden issued an Executive Order (E.O.) addressing certain outbound investments by U.S. persons in certain sensitive or advanced technologies or products involving certain “countries of concern.”...more

CFIUS Year in Review

CFIUS reviewed a record number of transactions in 2021 according to its most recent annual report – and shows no signs of slowing down. High technology (including quantum computing), life sciences, and green energy...more

Nicaragua Sanctions Update – November 2022

U.S. augments current sanctions on Nicaragua by imposing additional sanctions on the Nicaraguan mining authority and the former Nicaraguan head of state security, and expanding sanctions authorities allowing the U.S. to...more

Russia Sanctions Update - April 7, 2022

I. New Executive Order Bans U.S. Investment in Russia - On April 6, 2022, President Biden issued a new Executive Order, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to...more

Russia Sanctions Update – March 28, 2022

U.S. Sanctions - The U.S. continued to expand its Russia-related sanctions with new additions to the Specially Designated Nationals and Blocked Persons List (“SDN List”) made by the U.S. Department of the Treasury’s Office...more

Russia and Belarus Sanctions Update – March 17, 2022

On March 15, 2022, the U.S., UK, and EU announced new sanctions against various individuals and entities in connection with Russia’s invasion of Ukraine. The U.S. added certain human rights violators and senior Russian...more

Russia and Belarus Sanctions Update – March 15, 2022

On March 11, 2022, President Biden signed a new Russia-related Executive Order, Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression (“March 11 E.O.”)....more

Russia Sanctions Update March 7 2022 US Sanctions Export Restrictions Escalate as Conflict in Ukraine Continues

Key Takeaways: • U.S. imposes additional sanctions on Russian elites, along with their family members, companies, and personal vehicles • Actions targeting the defense sector and Russian government-affiliated media...more

Russia Sanctions Update – February 28, 2022: U.S. Imposes Sanctions on Central Bank of Russia, Ministry of Finance, and Sovereign...

On February 28, 2022, the U.S. government announced new sanctions on the Central Bank of Russia, National Wealth Fund, Ministry of Finance, and Russian Direct Investment Fund, dramatically increasing the economic impact of...more

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