The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
On May 23, 2025, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25 (“GL 25”), effectively lifting U.S. sanctions on Syria. This move follows President Trump’s announcement on...more
On January 8, 2025, the U.S. Department of Justice (DOJ) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by countries...more
On April 11, the DOJ announced steps towards the implementation of a national security program aimed at protecting Americans’ sensitive data from China, Russia, Iran and other foreign adversaries. The Data Security Program,...more
On January 8, 2025, the U.S. Department of Justice (“DOJ”) issued its final rule to implement Executive Order 14117 aimed at preventing access to Americans' bulk sensitive personal data and government-related data by...more
We previously covered President Trump’s IEEPA tariffs and the various retaliatory tariff and nontariff countermeasures announced by each country in separate posts. Currently, the Mexico and Canada tariffs have been paused...more
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
On October 29, 2024, the Department of Justice (“DOJ”) published its Notice of Proposed Rulemaking (“NPRM”) to implement President Biden’s Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data...more
The US Department of Justice issued a Notice of Proposed Rule Making (NPRM) October 21, 2024 that, if finalized, will prohibit or restrict a significant amount of international data sharing with countries of concern,...more
In addition to its well-publicized move to prohibit more than 150 million Americans from posting embarrassing dance videos of themselves on TikTok (at least while it is Chinese-owned), the U.S. federal government recently...more
On April 20, 2024, the House of Representatives passed H.R.8038, the 21st Century Peace through Strength Act ("supplemental"), which includes a version of H.R.7520, the Protecting Americans' Data from Foreign Adversaries Act...more
In a sweeping, coordinated effort across federal agencies, the US government has taken a giant leap forward to prevent access to data that could be exploited to the detriment of national security. On February 28, 2024,...more
On February 28, 2024, the Biden administration announced new cybersecurity-related measures, including an executive order (EO) and advance notice of proposed rulemaking (ANPRM), intended to address the bulk flow of Americans’...more
The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more
Last week, the Executive Order on Protecting the United States from Certain Unmanned Aircraft Systems (UAS) expanded the U.S.-China drone controversy to North Korea, Iran, and Russia....more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
The following is Part II of this article. Secondary Sanctions – Requirements On Non-U.S. Parties That Have No Contacts With the U.S. OFAC also has adopted sanctions that specifically apply to non-U.S. companies and...more
In 2018, the United States continued to expand its sanctions programs and increase enforcement. While President Donald Trump’s decision to re-impose nuclear-related sanctions on Iran has perhaps drawn the most attention, key...more
President Trump signed into law the Countering America’s Adversaries Through Sanctions Act (the CAATS Act) on August 2, 2017. The CAATS Act impacts sanctions related to Russia, Iran and North Korea....more
While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade...more
With the results in from the U.S. presidential election, companies should begin to consider the potential impact of a Trump presidency on their international business. U.S. economic sanctions were among the hot-button issues...more
Focusing on overseas cyber threats, President Obama issued an Executive Order on April 1, 2015, which grants authorization to impose sanctions on individuals and entities engaged "in malicious cyber-enabled activities that...more