After less than a week of a full-scale war between Russia and Ukraine, the post-Cold War global architecture appears irrevocably shattered, as Western nations line up to offer support and military and economic aid to Ukraine...more
3/1/2022
/ Airspace ,
Asset Freeze ,
Economic Sanctions ,
EU ,
Export Administration Regulations (EAR) ,
Export Controls ,
G7 ,
Popular ,
Russia ,
SWIFT ,
UK ,
Ukraine ,
United States
Back in July, we took a look at the enforcement actions for the first half of 2021 issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Today’s post – the second half of our OFAC 2021 Year...more
2/9/2022
/ Cloud Storage ,
Corporate Counsel ,
Digital Currency ,
Foreign Exchanges ,
Foreign Subsidiaries ,
Geolocation ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanctions ,
SDN List ,
U.S. Treasury ,
UK ,
Virtual Currency
2021 was a year of transition in the United States and for the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). OFAC’s year, while busy, was far different from 2020, as the Biden Administration’s...more
2/8/2022
/ Biden Administration ,
Burma ,
China ,
Corporate Counsel ,
Economic Sanctions ,
Forced Labor ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Iran ,
NDAA ,
NGOs ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
SDN List ,
U.S. Treasury
As we approach year’s end, and the pace of legislative activity ramps up, it remains critical to keep a close eye on the sanctions-related bills currently making their way, at varying speeds, through the U.S. legislative...more
11/9/2021
/ China ,
Corruption ,
Forced Labor ,
Foreign Policy ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury
After several years of foreign and domestic negotiations surrounding controls on intrusion software, the U.S. Department of Commerce’s Bureau of Industry & Security (BIS) published an interim final rule on October 21, 2021,...more
11/5/2021
/ Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Corporate Counsel ,
Cybersecurity ,
ECCNs ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Popular ,
Software ,
The Wassenaar Arrangement
As close observers of the Committee on Foreign Investment in the United States (“CFIUS” or “Committee”) are aware, the Committee has the authority to recommend that the President of the United States block a transaction on...more
As peak summer holiday season approaches, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) continues to remind the private sector of the importance of strict economic sanctions compliance. OFAC...more
7/15/2021
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Exchanges ,
ITSR ,
Moneygram ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
U.S. Treasury
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...more
4/20/2021
/ Biden Administration ,
Blocked Person ,
CBW Act ,
Cybersecurity ,
Defense Sector ,
Espionage ,
Executive Orders ,
Export Controls ,
Foreign Interference in US Elections ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Popular ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts ,
Technology Sector ,
Ukraine ,
Vladimir Putin
In too many ways to count, 2020 was an extraordinary year. As we move into 2021 with optimism for an end to the pandemic and better days ahead, we understand that the activity last year of the U.S. Department of the...more
2/16/2021
/ China ,
Corporate Counsel ,
Cuban Assets Control Regulations (CACR) ,
Customs and Border Protection ,
Department of Homeland Security (DHS) ,
Economic Sanctions ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Financial Institutions (FFI) ,
Iran Sanctions ,
Maritime Transport ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Pentagon ,
Pipelines ,
Popular ,
Ransomware ,
Russia ,
SDN List ,
Trump Administration
2020 brought the COVID-19 pandemic and other headline-grabbing challenges, along with “the usual” quadrennial questions around the U.S. election. Early in the year, businesses and dealmakers focused on the pandemic and...more
1/15/2021
/ Antitrust Division ,
CFIUS ,
Coronavirus/COVID-19 ,
Due Diligence ,
Economic Stimulus ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
EU Horizontal Safeguard Regulation (HSR) ,
Federal Trade Commission (FTC) ,
Human Rights ,
Initial Public Offering (IPO) ,
Loan Forgiveness ,
Loans ,
Material Adverse Events ,
Poison Pill ,
Popular ,
Private Equity ,
Remote Working ,
Representations and Warranties ,
Special Purpose Acquisition Companies (SPACs)
As the new crown virus is spreading and there have been many demonstrations that "blacks are also fate," the US Congress has increased its work during the election year, threatening to strengthen sanctions against China and...more
As we enter 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) may need time to catch its breath after an exceptionally busy year. 2019 showed us that the Trump Administration continues to rely on...more
On January 6, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule amending the Export Administration Regulations (EAR) to place new restrictions on the export of...more
Recently proposed legislation would substantially overhaul current law governing the Committee on Foreign Investment in the United States (CFIUS) by dramatically expanding CFIUS’ authorities and calling for CFIUS to take...more