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 March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The...more
4/1/2025
/ China ,
Corporate Counsel ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Imports ,
Settlement ,
Tariffs ,
Trump Administration ,
Whistleblowers
We are pleased to invite you to the inaugural D.C. Compliance & Government Investigations Seminar, hosted by Bass, Berry & Sims in collaboration with Watermark Strategies. This complimentary seminar will build upon the...more
3/28/2025
/ Best Practices ,
C-Suite Executives ,
Chief Compliance Officers ,
Chief Privacy Officer ,
Compliance ,
Continuing Legal Education ,
Emerging Technologies ,
Events ,
Federal Grants ,
Fraudulent Procurement ,
Government Agencies ,
Government Investigations ,
Regulatory Requirements ,
Trump Administration
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
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
• FIRRMA would significantly expand CFIUS jurisdiction.
• Mandatory filing would be required in some cases.
• Parties that protect and maintain personal information are likely to face more scrutiny....more
7/13/2018
/ CFIUS ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Controls ,
Filing Fees ,
Filing Requirements ,
FIRRMA ,
Foreign Acquisitions ,
Foreign Investment ,
Joint Venture ,
Jurisdiction ,
National Security ,
National Security Review Proceedings ,
Personal Data ,
Proposed Legislation ,
Risk Mitigation ,
Technology Sector ,
Trump Administration
• Previously permissible activities must be wound down in 90 or 180 days
• Non-U.S. companies at particular risk of enforcement action
• Only limited guidance issued so far, unclear what authority U.S. companies...more
• 7-year denial order imposed against Chinese telecommunications equipment maker
• Denial order strictly limits business with company
• Action comes as U.S. imposes other trade restrictions on China
On April 16, U.S....more
4/23/2018
/ CFIUS ,
China ,
Economic Sanctions ,
Export Controls ,
Exports ,
Mergers ,
National Security ,
Sanction Violations ,
Semiconductors ,
Telecommunications ,
Trump Administration
On March 12, 2018, President Trump blocked Broadcom, a Singapore-based semiconductor manufacturer, from pursuing the purchase of U.S.-based Qualcomm, a rival chip maker. Broadcom’s offer, reportedly for $117 billion or...more
This Post at a Glance -
- Company made false statements related to import duty charges
- Investigation initiated by whistleblower complaint from company’s competitor
- Trump Administration likely to impose...more
2/21/2018
/ Anti-Dumping Duty ,
China ,
Countervailing Duties ,
Customs ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
False Statements ,
Fraud ,
Furniture Industry ,
Government Investigations ,
Imports ,
Settlement Agreements ,
Tariff Classifications ,
Trump Administration ,
Underpayment ,
Unfair or Deceptive Trade Practices ,
Whistleblower Awards ,
Whistleblowers
- MoneyGram and Ant Financial mutually terminate $1.2 billion proposed merger
- CFIUS’s concerns focused on cyber and information security
- Scrutiny of buyers’ information security processes is likely to increase
On...more
1/22/2018
/ Acquisitions ,
CFIUS ,
China ,
Cross-Border Transactions ,
Cybersecurity ,
Data Security ,
Foreign Investment ,
Mergers ,
Moneygram ,
National Security ,
Technology Sector ,
Trump Administration
More Acquisitions May Be Blocked in the Future -
Last month, asserting national security concerns, President Trump blocked a $1.3 billion acquisition of Oregon-based Lattice Semiconductor by a subsidiary of the Canyon...more
Over the past month, we have closely monitored efforts by the U.S. Congress to tie the president’s hands over sanctions on Russia. Today, the president signed the Countering America’s Adversaries Through Sanctions Act...more
On June 19, 2017, the U.S. Senate overwhelmingly passed a bill mandating sanctions against Russia and Iran and a 30-day congressional review period should the president attempt to reduce those sanctions....more
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
In what may be a harbinger of things to come, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has issued new guidance regarding what may occur if the United States re-implements economic sanctions...more
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