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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
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
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
E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors. The prior Administration’s November 2020 Executive Order (E.O.) 13959...more
Many investors, traditional and progressive, are looking hard at cryptocurrency investments as a way to diversify their portfolios. However, there are still multiple known “unknowns” about this new market, including the...more
Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more