The dynamic pace of early policymaking by the new U.S. administration has continued into the spring of 2025, including in the context of sanctions on Venezuela. While Venezuela is not, and has not been, subject to...more
Policy change in Washington since the change in administration has been swift, dramatic in many areas and executed with unprecedented pace. One area, however, has been relatively stable in the administration’s first two...more
Over the past several years, as U.S. regulators have grappled with the increasing use of cryptocurrency across a spectrum of legitimate and illegitimate commerce, the U.S. Department of Commerce’s Office of Foreign Assets...more
3/28/2025
/ Appeals ,
Constitutional Challenges ,
Cryptocurrency ,
Delisting ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Smart Contracts ,
U.S. Treasury
The final regulations of the Outbound Investment Security Program, issued by the United States Department of the Treasury (the Treasury Department) on October 28, 2024 (the Final Rule), will become effective on January 2,...more
12/31/2024
/ Artificial Intelligence ,
Carve Out Provisions ,
China ,
Foreign Investment ,
Hong Kong ,
Initial Public Offering (IPO) ,
Limited Partnerships ,
Macau ,
National Security ,
Non-Public Information ,
Outbound Transactions ,
Recusal ,
Semiconductors ,
Technology Sector ,
U.S. Treasury
On November 21, 2024, the Biden Administration announced sweeping new sanctions targeting numerous Russian banks, financial institutions and officials, including one of the largest remaining unblocked Russian banks,...more
On February 23, 2024, the Biden Administration announced new sanctions targeting a number of different sectors of the Russian economy, Russian government officials and financial institutions, entities suspected of sanctions...more
3/11/2024
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
PRC ,
Russia ,
SDN List ,
U.S. Treasury ,
US Department of State
On October 18, 2023 the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a set of new authorizations under the Venezuela sanctions regime, including a temporary suspension of...more
On August 9, 2023, President Biden issued a long-awaited Executive Order establishing the legal authority for the U.S. Department of Treasury (“Treasury Department”) to institute an unprecedented regulatory regime restricting...more
As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more
On October 7, 2022, the Commerce Department Bureau of Industry and Security (“BIS”) – the primary gatekeeper on U.S. export controls – unleashed two lengthy and highly complex sets of regulations, aimed squarely at stopping...more
10/21/2022
/ Bureau of Industry and Security (BIS) ,
China ,
ECCNs ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Corporations ,
Foreign Direct Product Rule ,
Popular ,
Semiconductors ,
Technology Sector