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Venezuela Sanctions: Wind-Down of General License 41 and Introduction of ‘Secondary Tariffs’

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

New US Sanctions and Ongoing OFAC Designations Enable the New Administration’s Policy Priorities

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

A Whirlwind of Change: The Delisting of Tornado Cash

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

New U.S. Outbound Investment Restrictions on High-Technology Sectors in China

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

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