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Extraterritoriality Rules Economic Sanctions

BakerHostetler

Requiem for Task Force KleptoCapture: The Future of Russia Sanctions Enforcement

BakerHostetler on

On February 5, 2025, the new Attorney General announced the disbanding of Task Force KleptoCapture, which was launched in March 2022 to enforce the sweeping portfolio of sanctions against Russia. KleptoCapture was part of an...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

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

Holland & Knight LLP

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

Mayer Brown

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

Mayer Brown on

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

Venable LLP

Freight Forwarders and Common Carriers: As You Look Ahead to 2024, Do You "Know Your Cargo"?

Venable LLP on

As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more

Jones Day

CJEU Makes First Judgment Interpreting EU Blocking Regulation

Jones Day on

An Eagerly Awaited Decision - The Grand Chamber of the Court of Justice of the European Union ("CJEU") has recently— and for the first time—given its opinion on the interpretation and application of the controversial...more

K&L Gates LLP

Key Takeaways and Q&As to Understand China's Effort to Establish Its Own Legal Regime of Extraterritorial Jurisdiction

K&L Gates LLP on

On 10 June 2021, the Standing Committee of the National People’s Congress reviewed and approved the Anti-Foreign Sanctions Law (the AFSL), which took effect on the same day. The AFSL was enacted within two months and without...more

Jones Day

China Enacts Law to Counter Foreign Sanctions

Jones Day on

The Development: China's National People's Congress passed the Anti-foreign Sanctions Law (the "Anti-Sanctions Law") on June 10, 2021, which took effect immediately. The legislation was adopted by China in response to certain...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Blocking Rules Adopted in China May Force Companies To Choose Between US or China Law

On January 9, 2021, China’s Ministry of Commerce (MOFCOM) issued Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (Blocking Rules), effective immediately. The Blocking...more

Morgan Lewis

China’s New Blocking Statutes – MNCs Beware!

Morgan Lewis on

China’s Ministry of Commerce (MOFCOM) published the Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures (the Blocking Statutes) on January 9. The rules, which consist of...more

Pillsbury Winthrop Shaw Pittman LLP

China Publishes Blocking Statute to Counteract Unjustified Extraterritorial Application of Foreign Legislation and Sanctions

The Blocking Statute provides the legal basis for refusing to recognize, implement, and comply with unjustified extraterritorial application of foreign legislations and sanctions that prohibit or restrict normal economic,...more

WilmerHale

China Issues Blocking Rules to Counter Foreign Sanctions and Other Measures

WilmerHale on

On January 9, 2021, China’s Ministry of Commerce (“MOFCOM”) promulgated the Rules on Blocking Unjustified Extraterritorial Application of Foreign Legislation and Other Measures (阻断外国法律与措施不当域外适用办法) (“Blocking Rules”). The...more

Hogan Lovells

China reveals the Provisions on Unreliability Entity List

Hogan Lovells on

On 19 September 2020, China's Ministry of Commerce (MOFCOM) published the Provisions on the Unreliable Entity List (Order No.4 of 2020) (provisions), which immediately came into effect. It has been over one year since MOFCOM...more

White & Case LLP

Sanctioned default? The English High Court considers the effect of foreign illegality on English obligations

White & Case LLP on

As sanctions ramp up globally, it is increasingly important for commercial parties engaged in cross border transactions to have certainty (i) as promisees (e.g. lenders) as to when their counterparties may legitimately avoid...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

BCLP

The publication of the Gauvain report on the protection of French companies against extraterritorial laws and measures

BCLP on

The Gauvain Report to "Restore the sovereignty of France and Europe and protect our companies from laws and measures with extraterritorial scope" was submitted to the French Prime Minister on 26 June 2019. As its name...more

Akin Gump Strauss Hauer & Feld LLP

Podcast: U.S. Sanctions and Their Impact on Non-U.S. Businesses

In this podcast, Akin Gump’s international trade partners Mahmoud Baki “Mac” Fadlallah (Dubai), Jasper Helder (London) and Wynn Segall (Washington, D.C.) discuss three pivotal regions related to U.S. sanctions under the...more

Foley & Lardner LLP

Recent Enforcement Actions Demonstrate Multinational Automotive Companies Should Conduct Risk Assessments

Foley & Lardner LLP on

Regulators within the Trump administration have sent a loud message that should concern all multinational automotive companies: laws governing international activities continue to be the subject of intense enforcement...more

Orrick, Herrington & Sutcliffe LLP

ZTE Trade Controls Denial Order – Four Crucial Points

On April 15, 2018, the U.S. Commerce Department's Bureau of Industry and Security ("BIS") imposed a "denial order" against Zhongxing Telecommunications Equipment Corporation ("ZTE Corporation") and ZTE Kangxun...more

Orrick, Herrington & Sutcliffe LLP

Venezuela Debt Restructuring – Sanctions Compliance

As parties pursue restructuring of Venezuelan sovereign debt, they should be sensitive to U.S. economic sanctions prohibitions. The sanctions prohibitions broadly apply to "U.S. persons" – U.S. citizens and permanent...more

Akin Gump Strauss Hauer & Feld LLP

U.S. State Department Issues Belated List and Guidance on Extraterritorial Sanctions Affecting Russian Defense and Intelligence...

• On October 27, 2017, the U.S. State Department issued guidance identifying 39 entities related to the defense and intelligence sectors of the Government of the Russian Federation and issued related guidance on criteria to...more

Jones Day

Germany: Termination for Breach of US Regulatory Rules Not Permissible, European Labour & Employment Update

Jones Day on

The New York State Department of Financial Services ("NYDFS") required Commerzbank to terminate the employment of a Germany-based employee on the basis that he played "a central role" in the breaching of US sanctions...more

Foley & Lardner LLP

New Administration Ramps up Enforcement Efforts

Foley & Lardner LLP on

The Trump administration has vowed to bring jobs back to the states. One of the methods it appears it’ll take advantage of is continued, aggressive enforcement of U.S. laws governing exports and international conduct....more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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