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Dorsey & Whitney LLP

Trump Administration Modifies Tariff Actions under National Security Powers

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Not long after announcing new global “reciprocal” tariffs on imports from around the world at the beginning of April 2025, which we previously reported in a recent eUpdate, President Trump began modifying that tariff action....more

Bracewell LLP

Trump Administration Efforts to Eliminate Cartels Pose Heightened Risk for Financial Institutions

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As discussed in Bracewell’s February 11 and February 26 updates, the executive branch is prioritizing the “total elimination” of cartels and transnational criminal organizations, both through edicts from the Oval Office and...more

K2 Integrity

The Tornado Cash Delisting And Sanctions Compliance Implications For Crypto

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On 21 March 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) removed Tornado Cash, a virtual currency mixer, from its list of Specially Designated Nationals and Blocked Persons (SDN List),...more

DLA Piper

Trump Administration Designates Eight Transnational Organizations as Foreign Terrorist Organizations and Specially Designated...

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Effective February 20, 2025, the Secretary of State designated eight Latin American organizations as Foreign Terrorist Organizations (FTOs) under Section 219 of the Immigration and Nationality Act (INA) and as Specially...more

Skadden, Arps, Slate, Meagher & Flom LLP

Trump’s Tariffs on Canada, Mexico and China: Update and Analysis

On February 1, 2025, President Donald Trump signed executive orders imposing tariffs on almost all imports from Canada, Mexico and China. Tariffs on China became effective on February 4, 2025, while Canada and Mexico reached...more

Hogan Lovells

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

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The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

Orrick, Herrington & Sutcliffe LLP

DOJ Seeks to Restrict Data Transfers to ‘Countries of Concern’

The Department of Justice (DOJ) has proposed a significant restriction on cross-border transfers of sensitive personal data to designated “countries of concern.” The goal is to address national security risks posed by...more

Skadden, Arps, Slate, Meagher & Flom LLP

President-Elect Trump Announces Intent To Impose Tariffs on Goods Imported From Canada, Mexico and China

On November 25, 2024, President-elect Donald Trump announced that, on his first day in office, he would impose new tariffs on all imports from Canada, Mexico and China. Specifically, in posts on the social media platform...more

Seward & Kissel LLP

Changes Are Coming

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Elections, as they say, have consequences. That bit of political wisdom certainly will be true again this time around—our president-elect has been announcing appointees for cabinet positions that are bound to bring about...more

Latham & Watkins LLP

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

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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

Morrison & Foerster LLP

War Aid and Sanctions: National Security Act Includes Significant New Sanctions Authorities

On April 24, 2024, President Biden signed into law a long-debated $98 billion foreign aid and national security legislative package (the “Act”) providing funds for Israel, Taiwan, and Ukraine, and authorizing new sanctions...more

K2 Integrity

The North Korean Crypto Threat

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Executive Summary - The North Korean threat to the crypto ecosystem is the highest form of immediate risk to the crypto-economy driven by a regime that seeks to profit from its misuse to reinforce its regime and fuel all its...more

Bilzin Sumberg

OFAC Issues Regulatory Advisory Warning Against Facilitating Ransomware Payments

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On October 1, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an “Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” The Advisory, which does not carry the...more

Morgan Lewis

Implications for Chinese Investment in the US After Section 301 Report

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Section 301 provides the president with broad authority to implement new policies and procedures that could impact reviews of Chinese investment in the United States. The president could rely on the International Emergency...more

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