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A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and...more

OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion

On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including: 1. Expanding the scope of financial sanctions:...more

E(U)xterritoriality of EU Sanctions: The No Russia Clause

The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick. As a general rule, EU regulations do not apply extraterritorially. This policy is a bit pointed, intended to stand...more

The EU’s 11th Sanctions Package: The Long(er) Arm of the Law

On June 23, 2023, the EU released its 11th package of sanctions on Russia. This package is designed to improve enforcement with new anti-circumvention rules, new trade restrictions, and new designations. The...more

Everything but the Kitchen Sink (and Maybe That Too!): New Export Controls on Russia Cover Whole Categories of Low-Level...

The United States and its allies are aiming to choke off the supplies that support the last vestiges of Russian industry. On May 19, 2023, the Bureau of Industry and Security (BIS) released new regulations implementing...more

Watching the Detectives: Export Control Enforcement Trends Upward

Between Russia’s invasion of Ukraine and growing U.S. tensions with China, U.S. export controls are in the spotlight like never before. As if regulators have not already made it clear enough, recent statements and actions...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

Introduction of internet-related Russia trade sanctions in the UK

On April 29, 2022, the UK introduced new measures to prevent the provision of internet services to or for the benefit of designated persons. These measures apply to the whole territory of the UK and to conduct by UK persons...more

The Government Contractor’s Guide to (Not) Doing Business with Russia

The United States is engaging in a new form of warfare. Russia invaded Ukraine just over two months ago and, rather than join the fight directly by sending troops to defend Ukraine, the United States is fighting indirectly by...more

Additional Import and Export Restrictions in Response to Russia’s Aggression in Ukraine

Last week, the United States government imposed additional restrictions on the imports from, and exports to, Russia. The import changes stem from the Suspending Normal Trade Relations with Russia and Belarus Act, signed into...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine (update)

Updated as of April 12, 2022 - It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed...more

U.S. and Allies Impose Additional Severe Costs on Russia for Atrocities in Ukraine

It has now been more than 40 days since the start of Putin’s brutal invasion of Ukraine. Today, following the recent revelations of the atrocities committed in Bucha, Ukraine by Russian armed forces, the United States – in...more

Crypto and Russia Sanctions: A Primer and Survival Guide For Crypto Companies

The recent comprehensive economic sanctions by the U.S. and other nations against Russia has propelled the crypto community onto the geo-political stage in a major way. As with other forms of payment and methods of money...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New U.S. Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of OFAC (Treasury) and BIS (Commerce) Actions - Major Russian Banks Blocked from the U.S. Financial System. Six major Russian banks — VEB, Promsvyazbank (PSB), VTB Bank,...more

Russian Risk: Transactions with Russian Banks and Exports to Russia Create Greatest Exposure Under New EU and UK Ukraine-Related...

Updated as of February 25, 2022 - Key Takeaways of EU and UK Recent Actions Against Russia and Ukraine Breakaway Regions - The EU adopted the first tranche of sanctions restrictions targeting financial institutions, other...more

U.S., UK and EU Sanctions Over Putin’s Recognition of Breakaway Ukraine Regions

U.S. Comprehensive Sanctions Against the DNR and the LNR - Scope: the DNR and LNR - The new EO does not detail which parts of the Donetsk and Luhansk regions[1] are subject to the new U.S. sanctions. It is likely that...more

Arming for a Trade War: The EU Proposes an Unprecedented Anti-Coercion Regulation

Scope of the Proposed Regulation - The Regulation would apply where a third country interferes in the legitimate sovereign choices of the Union or a Member State, by applying or threatening to apply measures affecting...more

A Ruble Without a Cause: What Economic Sanctions on Russia May Mean for Your Business and Global Finance

With Russian forces massing at the Ukrainian border, the U.S. and EU have been warning of severe economic sanctions. While we wait and watch this brinksmanship play out, it is worth considering how businesses, and...more

The Next Four Years in International Business

Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before...more

Movements Without Motion In Russian Sanctions Policy

Since the U.S. government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. Twice in 2016, the United States implemented sanctions...more

2/12/2018  /  CAATSA , Economic Sanctions , Russia

Lurches, Leaps, Feints, and Flops: Movements Without Motion in Russian Sanctions Policy

Since the U.S. Government determined that Russia interfered in the 2016 election, movement around Russia sanctions policy has been vigorous, if not unidirectional. In 2016, the United States implemented twice sanctions...more

In the Chaos of (Trade) War, Where Does Your Company Find Peace?

On July 27, 2017, the U.S. Congress sent to President Trump’s desk a bill that imposes new financial sanctions against Russia, Iran, and North Korea. It appears nearly certain that the president will sign that bill, now...more

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