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International Emergency Economic Powers Act (IEEPA) Biden Administration

Benesch

Update: Reciprocal Tariff “Pause” Deadline Extension and New Duty Rates

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The White House has extended the July 9, 2025, deadline for its “pause” on reciprocal tariffs. An Executive Order released on the evening of July 7 extends this deadline to August 1, 2025....more

WilmerHale

The United States and European Union Offer Sanctions Relief to Post-Assad Syria

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Following the fall of Syria’s Assad regime, the United States and key allies have recently announced sanctions relief with the stated goal of stabilizing Syria under its newly installed leaders. ...more

Holland & Knight LLP

U.S. Health Data Affected by New National Security Restrictions on International Data Transfers

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Health Insurance Portability and Accountability Act (HIPAA)-covered entities and business associates should be familiar with restrictions on the use or disclosure of protected health information (PHI) under HIPAA rules....more

White & Case LLP

United States Begins to Restrain Cross-Border E-commerce

White & Case LLP on

E-commerce platforms and others could face significant challenges due to recent and proposed changes to de minimis entry (the process for importing products without tariffs and with simplified customs procedures if the total...more

Hinch Newman LLP

DOJ Issues Rule Addressing Threat Posed by Foreign Adversaries’ Access to Americans’ Sensitive Personal Data

Hinch Newman LLP on

On Friday, December 27, 2024, the Justice Department issued a final rule to address “urgent national security risks posed by access to U.S. sensitive personal and government-related data from countries of concern and covered...more

Bracewell LLP

An "Immutable" Force Meets an Immovable Object: OFAC's Crypto Loss at the Fifth Circuit

Bracewell LLP on

On November 26, 2024, the US Court of Appeals for the Fifth Circuit ruled that “immutable” smart contracts are not “property” for purposes of regulation by the US Department of the Treasury’s Office of Foreign Assets Control...more

WilmerHale

DOJ Issues NPRM Regarding Sensitive Data Transfers

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With the publication of a recent Notice of Proposed Rulemaking (NPRM), the Department of Justice National Security Division will soon become an important new regulator of transactions involving the transfer of sensitive U.S....more

Wiley Rein LLP

DOJ and CISA Propose New National Security Program to Regulate Foreign Access to Sensitive Data

Wiley Rein LLP on

On October 21, 2024, the U.S. Department of Justice (Department or DOJ) and the U.S. Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) issued proposals – required by the...more

King & Spalding

Biden Administration Issues Proposed Rule Targeting “Connected Vehicles” Tied to China or Russia

King & Spalding on

The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more

Husch Blackwell LLP

OFAC Issues Guidance Extending Statute of Limitations to 10 Years

Husch Blackwell LLP on

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal...more

White & Case LLP

Sanctions move up the agenda for lenders and borrowers

White & Case LLP on

Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

Latham & Watkins LLP on

The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Skadden, Arps, Slate, Meagher & Flom LLP

Security Assistance Law Expanded the Reach of US Sanctions and Doubled the Statute of Limitations

On April 24, 2024, President Joe Biden signed the 21st Century Peace Through Strength Act (Act) into law. The Act, which is part of a broader law providing supplemental aid to Israel, Taiwan and Ukraine, contains several...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

The Volkov Law Group on

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Benesch

New Statute of Limitations Impacts M&A and International Trade Compliance

Benesch on

New developments in international trade laws will have tangible and far-reaching impacts on transactions as well as day-to-day business operations.  President Biden’s signing of HR 815 means that once time-barred historic...more

Blank Rome LLP

President Biden Signs into Law Ten-Year Statute of Limitations for Sanctions Violations and Other National Security Measures

Blank Rome LLP on

President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more

Alston & Bird

National Security Act Ushers In Sweeping Changes to Sanctions Regulations

Alston & Bird on

On April 24, 2024, President Biden signed H.R. 815, otherwise known as the National Security Act of 2024. The bill provides emergency appropriations for Ukraine, Israel, Taiwan, humanitarian purposes in Gaza, and various...more

Ankura

Operational Implications of the New Bulk Sensitive Data Executive Order

Ankura on

On February 28, 2024, President Biden signed Executive Order 14117 (the EO), on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The United...more

Sheppard Mullin Richter & Hampton LLP

Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations

Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been...more

BakerHostetler

Current State of U.S. Economic Sanctions Imposed in Response to Russia’s Invasion of Ukraine - May 2024

BakerHostetler on

In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

Womble Bond Dickinson on

President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

Fenwick & West LLP

Sanctions Violations: New 10-Year Statute of Limitations

Fenwick & West LLP on

On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...more

Mayer Brown

US Congress Extends Statute of Limitations for Sanctions and Export Controls

Mayer Brown on

On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more

Robinson & Cole LLP

Data Privacy + Cybersecurity Insider - March 2024 #2

Robinson & Cole LLP on

CYBERSECURITY - CISA, FBI + MS-ISAC Issue Warning on Phobos Ransomware - To help organizations protect against ransomware, CISA, the FBI, and the Multi-State Information Sharing and Analysis Center (MS-ISAC) released a...more

The Volkov Law Group

President Biden Issues Executive Order Concerning Bulk Data, With Parallels to Current Sanctions Regulations

The Volkov Law Group on

On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States.  By issuing his Executive Order...more

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