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DOJ Hits Play: The End of the FCPA “Pause” and Return to Enforcement

On June 9, 2025, the Deputy Attorney General issued a Memorandum detailing the administration’s new FCPA guidelines for all current and future investigations and enforcement actions. According to the Head of DOJ’s Criminal...more

Trump Administration Issues Sweeping Sanctions Relief for Syria

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025...more

The European Response to DOJ’s FCPA Enforcement “Pause”

On March 20, 2025, the United Kingdom, France and Switzerland jointly announced the formation of a new International Anti-Corruption Prosecutorial Taskforce (the “Task Force”) aimed at strengthening cross-border collaboration...more

President Trump Places His Early Mark on Export Controls

Howard Lutnick has been confirmed as Secretary of Commerce, while Jeffrey Kessler has been nominated for Under Secretary for Industry and Security. Both have more experience with trade policy and tariffs than with export...more

Biden Administration Revamps Sanctions Program Targeting Publicly Traded Securities of Designated Chinese Military Companies

On June 3, 2021, President Biden issued Executive Order 14032 (Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China) (“CMIC EO”) that modifies the Trump-era...more

U.S. Government Authorizes Economic Sanctions on Turkey

• A new Executive Order signed October 14, 2019, authorizes U.S. sanctions related to the military conflict between Turkey and Syria, providing broad authority to impose sanctions against Turkish government agencies,...more

Trump Administration Expands Sanctions Targeting Iran’s Industrial Metals Sector

• President Trump issued a new Executive Order (EO) on May 8, 2019—exactly one year after the Trump administration withdrew from the Iran nuclear deal—that widened the scope of existing sanctions targeting the Iranian...more

President Trump Declares National Emergency to Secure the Information and Communications Technology and Services Supply Chain

• On May 15, 2019, President Trump issued a long-awaited E.O. designed to curtail the use of telecommunications items and services from certain countries and persons in U.S. networks. The E.O. does not impose immediate...more

OFAC Sanctions Venezuelan State-Owned Energy Company PdVSA, Releases New General Licenses and FAQs for Venezuela Sanctions Regime

• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List. • As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

United States Imposes New Sanctions Restricting Transactions with the Government of Venezuela

• On May 21, 2018, the Trump administration imposed new sanctions on the Government of Venezuela in response to the reelection of President Maduro and the “deepening humanitarian and public health crisis” fueled by the Maduro...more

OFAC Sanctions Leading Russian Businessmen, Government Officials and Companies

• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Trump Administration Significantly Expands Sanctions Against North Korea

On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more

Trump Administration Makes First Iran Sanctions Designations

Key Points - - The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more

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