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The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more
On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 under the Syrian Sanctions Regulations, marking a measured but far-reaching reconfiguration of...more
On May 23, 2025, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25, which provides broad authorization for U.S. persons to engage in dealings prohibited under the Syrian Sanctions...more
In its FAQs, U.S. Custom and Border Protection (CBP) clarified the exemption from reciprocal tariffs for goods subject to steel/aluminum Section 232 duties under HTSUS 9903.01.33. CBP clarified that the exemption only applies...more
On February 21, 2025, President Trump issued a memorandum titled "America First Investment Policy" (the “Policy”), outlining new measures to shape U.S. investment policy. Though the Policy makes it clear that the United...more
On February 21, 2025, President Trump issued the America First Investment Policy Memorandum, which emphasizes the U.S. commitment to a strong, open investment environment while reshaping the U.S. government’s policy towards...more
On February 21, 2025, a Presidential Memorandum, “America First Investment Policy” (the “Memorandum”), announced planned changes to the Committee on Foreign Investment in the United States (“CFIUS”) and outbound investment...more
Tandis que la future administration Trump se prépare à prendre ses fonctions, de nombreuses évolutions, tant au niveau réglementaire qu’en matière de mise en œuvre des règlementations par les autorités américaines compétentes...more
As we wrote previously, the U.S. Department of the Treasury has issued a final rule that takes effect on December 26 that will dramatically raise the Committee on Foreign Investment in the United States (CFIUS) penalties from...more
The Notice of Proposed Rulemaking (NPRM or the Proposed Rule), issued by Treasury on June 21, 2024, would implement President Biden’s August 9, 2023, Executive Order on outbound investment, which addresses concerns related to...more
On February 8, OFAC published Russia-related FAQ 1113 to clarify whether new investment prohibitions in Executive Order (E.O.) 14066, E.O. 14068, or E.O. 14071 prohibit U.S. persons, including U.S. financial institutions,...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. This week, we reviewed the recent...more
The Week in Review delivers the impact and analysis for the public, private, and non-profit sectors from our daily reporting of the evolving global sanctions campaign against Russia. ...more