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Enforcement Actions China Economic Sanctions

The Volkov Law Group

BIS Levies $4.25 Million Penalty Against Alpha and Omega Semiconductor for Unauthorized Exports to Huawei

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On June 27, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order resolving administrative enforcement proceedings against Alpha and Omega Semiconductor Incorporated (“AOS”), a...more

Wiley Rein LLP

Update: Enforcement of DOJ Data Security Program Set to Begin July 9

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The U.S. Department of Justice (DOJ) is set to enforce its sweeping new rule on certain U.S. data transactions with countries of concern and covered persons as of July 9, 2025. The new rule regarding “Preventing Access to...more

Morrison & Foerster LLP

FinCEN Targets Three Mexico-Based Financial Institutions with Sanctions Under New Authority to Address Money Laundering Associated...

On June 25, 2025, FinCEN issued its first orders under the 2024 FEND Off Fentanyl Act (FOFA), imposing special measures against three Mexican financial firms—CIBanco S.A., Institución de Banca Múltiple (CIBanco), Intercam...more

White & Case LLP

EU imposes first International Procurement Instrument measure restricting Chinese access to medical devices procurement

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Adopted in 2022, the IPI allows the Commission to investigate alleged non-EU country measures or practices against EU economic operators that limit access to the public procurement and concession markets of non-EU countries....more

Morrison & Foerster LLP

Enforcement of China’s Anti-Foreign Sanctions Law Strengthens Through Private Cause of Action and New Implementing Rules

In November 2024, in the first successful private cause of action under the Anti-Foreign Sanctions Law (AFSL), a Chinese court adjudicated a civil claim by a Chinese company against its overseas customer for failure to pay...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ White Collar Enforcement Plan Continues To Present Risks for Non-US Companies

Matthew Galeotti’s recent memorandum as head of the Department of Justice’s (DOJ’s) Criminal Division echoes the Trump administration’s “America First” priorities. It directs the Criminal Division to “strike an appropriate...more

Seward & Kissel LLP

DOJ Implements New Data Security Program: Data Transfer Restrictions with a National Security Focus

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Effective as of April 8, 2025, the National Security Division of the U.S. Department of Justice (DOJ) has implemented a Data Security Program (the DSP) to address national security risks associated with the transfer of...more

Jones Day

China Boosts Enforcement of Anti-Foreign Sanctions Law

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China has recently taken several actions showing its commitment to counter trade restrictions imposed by other countries. In March 2025, it released regulations implementing the 2021 Anti-Foreign Sanctions Law. In tandem with...more

ArentFox Schiff

As the (Customs and Trade) World Turns: April 2025

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Welcome to the April 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Troutman Pepper Locke

Trump Administration’s First Export Control Action – Reading the Tea Leaves

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On March 25, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced a significant expansion of its Entity List restrictions, adding 80 entities from China, the United Arab Emirates, South Africa,...more

Foley Hoag LLP - White Collar Law &...

Review of International Trade Enforcement in the U.S., E.U., and UK in 2024 and What to Expect in 2025

This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more

The Volkov Law Group

Haas Automation Fined $2.5 Million for Export Control and Sanctions Violations Involving China and Russia

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In one of the first enforcement actions of 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final order against Haas Automation, Inc., a leading manufacturer of computer numerical...more

Clark Hill PLC

The Department of Homeland Security Makes the Largest Additions Thus Far to the UFLPA Entity List

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Just as the year started, the Department of Homeland Security (“DHS”) announced the addition of 37 companies to the Uyghur Forced Labor Prevention Act (“UFLPA”) Entity List, bringing the total number of entities on the list...more

Skadden, Arps, Slate, Meagher & Flom LLP

Political Changes Are Unlikely To Fundamentally Alter Key Sanctions

Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more

American Conference Institute (ACI)

[Event] Advanced Forum on Global Export Controls - February 25th - 26th, Arlington, VA

Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more

Alston & Bird

OFAC Announces Sanctions Against Chinese-Based Cybersecurity Company

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On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sanctions Puzzle: Key Areas To Watch in 2025 and Beyond

The past weeks and months have brought about tremendous political change in the West, as we move toward a new U.S. administration, a new College of Commissioners in Brussels and a new Polish presidency of the Council of the...more

WilmerHale

MOFCOM Initiates Investigation into PVH Group Under China’s Unreliable Entity List Regime

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On September 24, the Bureau of Industry, Security, Import and Export Control (BISIEC) of the Ministry of Commerce (MOFCOM) announced a formal investigation under China’s Unreliable Entity List (UEL) regime into PVH Group, a...more

Braumiller Law Group, PLLC

Braumiller-Law-Group - June 2024 Newletter

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

The Volkov Law Group

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

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Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - July 26th, Singapore, Singapore

Looking for compliance education and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer convenient, local compliance education for practitioners in a variety of locations across the globe, and...more

Morrison & Foerster LLP

OFAC Year in Review 2023 – Part 1

2023 was another record year for U.S. sanctions and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Most prominently, OFAC continued to impose significant additional sanctions on Russia in...more

American Conference Institute (ACI)

[Event] New York Forum on Economic Sanctions - December 13th - 14th, New York, NY

Back by popular demand, ACI’s acclaimed 13th Annual New York Forum on Economic Sanctions returns to NYC this December. Regarded as the must attend conference for legal and compliance professionals working for financial...more

American Conference Institute (ACI)

[Event] 5th Conference on U.S.-China Trade Controls - October 12th - 13th, Washington, DC

As the only comprehensive, practical event of its kind in the Unites States, ACI is hosting the highly anticipated 5th Annual U.S.-China Trade Controls Conference, scheduled for October 12–13 in Washington, DC. Considering...more

Guidepost Solutions LLC

The China Syndrome: Competing Regimes Make Due Diligence a Tall Task

...While reliable information from China has always come at a premium, recent restrictions on previously available business intelligence as well as Chinese enforcement actions against foreign investigative diligence firms are...more

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