The US Treasury Department has released its 2021 Sanctions Review (the “Review”), which describes the US sanctions framework and the agency’s future sanctions priorities. The Review reflects on the evolution over two decades...more
10/20/2021
/ China ,
Corporate Counsel ,
Economic Sanctions ,
EU ,
Hong Kong ,
Iran ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Public Policy ,
Russia ,
U.S. Treasury ,
Venezuela ,
Virtual Currency
On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
3/23/2021
/ Biden Administration ,
China ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border ,
Cuba ,
Foreign Adversaries ,
Hong Kong ,
Interim Final Rules (IFR) ,
Iran ,
Licensing Rules ,
National Security ,
North Korea ,
Russia ,
Safe Harbors ,
Supply Chain ,
Technology ,
Telecommunications ,
U.S. Commerce Department ,
Venezuela
On December 28, 2020, the Department of the Treasury Office of Foreign Assets Control (OFAC) published awaited guidance on the implementation of Executive Order (EO) 13959, “Executive Order on Addressing the Threat from...more
On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more
7/2/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Defense Sector ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Final Rules ,
General Licenses ,
National Security ,
Russia ,
Technology ,
U.S. Commerce Department ,
Venezuela
On May 15, 2020, the US Department of Commerce announced a rule further targeting Chinese telecommunications company Huawei and its chip-making subsidiary HiSilicon for allegedly engaging in “stepped-up efforts to undermine”...more
On December 13, 2019, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) issued a revised policy regarding voluntary disclosure of export control and sanctions violations by business organizations...more
12/27/2019
/ Amended Regulation ,
Arms Export Control Act ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
Directorate of Defense Trade Controls (DDTC) ,
Economic Sanctions ,
Enforcement Guidance ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
ITAR ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Standards ,
Voluntary Disclosure ,
Willful Blindness ,
Willful Misconduct
After decades in which the Foreign Agents Registration Act (FARA) received relatively little attention, a confluence of recent events has given the statute newfound prominence. Together, these developments compound the...more
3/11/2019
/ Advisory Opinions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Exemptions ,
Foreign Agents ,
Foreign Agents Registration Act (FARA) ,
Foreign Governments ,
Foreign Nationals ,
Lobbying ,
Lobbying Disclosure Act ,
National Security ,
Recordkeeping Requirements ,
Reporting Requirements
On August 1, 2018, the US Department of Commerce Bureau of Industry and Security (BIS) published a Federal Register notice stating that the US government had identified 44 Chinese companies as acting contrary to US national...more