On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has...more
On July 11, the Trump administration issued an order blocking and requiring the unwinding of a 2020 acquisition by which Jupiter Systems, LLC (Jupiter), a U.S.-based audiovisual equipment supplier, was acquired by Suirui...more
On June 9, Deputy Attorney General Todd Blanche issued a memorandum entitled Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (the Memo) addressed to the head of the Criminal Division of the...more
6/13/2025
/ Anti-Corruption ,
Bribery ,
Corporate Governance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
White Collar Crimes
On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and...more
3/3/2025
/ CFIUS ,
China ,
Critical Infrastructure Sectors ,
Executive Orders ,
Foreign Investment ,
International Trade ,
Investment ,
Legislative Agendas ,
National Security ,
Regulatory Agenda ,
Technology Sector ,
Trump Administration
In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the...more
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
1/10/2024
/ Commodities ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Financial Institutions (FFI) ,
International Trade ,
Maritime Transport ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Regulatory Reform ,
Russia ,
Sanction Violations ,
U.S. Commerce Department ,
U.S. Treasury
On October 20, the Committee on Foreign Investment in the United States (CFIUS) released new, non-binding Enforcement and Penalty Guidelines (Guidelines). The Guidelines follow upon last month’s Executive Order linking CFIUS...more
...President Biden Extends National Emergency under Executive Order 14024 -
On April 13, President Biden extended the national emergency declared under Executive Order (EO) 14024 for an additional year due to the harmful...more
4/19/2022
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Financial Institutions ,
Joe Biden ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Commerce Department ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/8/2022
/ Airlines ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Export Terminals ,
Financial Institutions ,
Financial Transactions ,
Russia ,
Travel Restrictions ,
U.S. Commerce Department
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes new U.S. sanctions and...more
4/6/2022
/ Belarus Sanctions ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Foreign Trade Regulations ,
General Licenses ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
The Bass, Berry & Sims international trade team is actively monitoring the situation in Russia and Ukraine and providing real-time advice to clients on managing the situation. This post summarizes the evolving situation as of...more
3/15/2022
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Foreign Investment ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Monday, February 28, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This post supplements our post of late evening on...more
3/1/2022
/ Asset Freeze ,
Banks ,
Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
Financial Institutions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine
This UPDATED post summarizes the situation as of late evening on Thursday, February 24, concerning current U.S. sanctions and export restrictions related to Russia and Ukraine. This supplements our post of late evening on...more
On February 22, President Biden issued Executive Order14,024 (the EO), which authorizes the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) to designate Russian and other entities and individuals involved in...more
2/24/2022
/ Biden Administration ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Financial Institutions ,
Foreign Policy ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Ukraine
On November 10, the U.S. Departments of State, Treasury, and Commerce issued an unusual joint advisory (the “advisory”) on the risk of investing and interacting with certain Cambodian individuals and entities. The advisory is...more
12/8/2021
/ Cambodia ,
Corruption ,
Executive Orders ,
High-Risk Countries ,
Office of Foreign Assets Control (OFAC) ,
Risk Factors ,
Sanctions ,
Trade Restrictions ,
U.S. Commerce Department ,
U.S. Treasury ,
US Department of State
• $2 million penalty against Exxon overturned
• Court concluded that OFAC failed to provide clear notice of violative conduct
• Companies are at risk when acting in context of ambiguous agency guidance
At the end of...more
1/22/2020
/ Civil Monetary Penalty ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Guidance ,
Executive Orders ,
Exxon Mobil ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Prohibited Transactions ,
Reversal ,
Rosneft ,
Russia ,
Sanction Violations ,
SDN List ,
Ukraine ,
Vacated
The U.S. Treasury Department, Office of Foreign Assets Control (OFAC), the main U.S. government body that administers U.S. economic sanctions and embargoes, continues to be busy. In September 2019 alone, OFAC has announced...more
9/27/2019
/ China ,
Economic Sanctions ,
Executive Orders ,
Foreign Corrupt Practices Act (FCPA) ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Settlement Agreements ,
Sudan ,
Trade Relations ,
Trump Administration ,
Unfair or Deceptive Trade Practices ,
Venezuela
• Virtually all transactions with government prohibited
• Most transactions with private sector parties still permitted
• Practical challenges make Venezuela transactions difficult, including for non-U.S. parties
On...more
• OFAC proposes new reporting requirement for rejected transactions
• Agency issues guidance on dealing with Iran
• Additional parties designated under Magnitsky sanctions program
• Careful diligence of...more
8/1/2019
/ Aviation Industry ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Interim Final Rules (IFR) ,
Iran Sanctions ,
Magnitsky Act ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
SDN List ,
Trade Relations ,
Trump Administration ,
Unfair or Deceptive Trade Practices
• Economic sanctions and export restrictions extended
• Russian investment in United States likely subject to heightened scrutiny
• Diligence on Russia transactions and business partners is essential to ensure...more
9/27/2018
/ CAATSA ,
CBW Act ,
CFIUS ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Exports ,
FIRRMA ,
Foreign Investment ,
Foreign Policy ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
Trump Administration ,
U.S. Treasury
- Virtually all U.S. sanctions on Sudan lifted effective January 17, 2017
- Sanctions could be permanently lifted in six months
- There continue to be practical challenges to doing business in Sudan...more
1/19/2017
/ Barack Obama ,
Economic Sanctions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
General Licenses ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Revocation ,
State Sponsors of Terrorism ,
Sudan
For those of us who live and breathe U.S. economic sanctions, we are used to most people largely ignoring what goes on in our world. The United States’ recent imposition of new sanctions against Russia, however, was not one...more
1/4/2017
/ Barack Obama ,
CIA ,
Congressional Investigations & Hearings ,
Cyber Attacks ,
Cyber Crimes ,
Economic Sanctions ,
Executive Orders ,
FBI ,
Office of Foreign Assets Control (OFAC) ,
Presidential Elections ,
Public Officials ,
Russia ,
SDN List ,
Trump Administration ,
Vladimir Putin
With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more
11/22/2016
/ Barack Obama ,
Cuba ,
Economic Sanctions ,
Executive Orders ,
Federal Contractors ,
General Licenses ,
Iran ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Repeal ,
Russia ,
Trump Administration