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The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we...more
The Trump Administration is aggressively pursuing export controls and sanctions enforcement. In two separate cases, the Treasury Department’s Office of Foreign Asset Control and the Commerce Department’s Bureau of Industry...more
What happens when companies ignore red flags, bypass legal advice, and underestimate the reach of U.S. export laws? In this episode, Michael Volkov unpacks two major enforcement actions from the Department of Commerce’s...more
On June 30, 2025, the White House issued Executive Order 14312, Providing for the Revocation of Syria Sanctions (the Syria EO), terminating U.S. comprehensive sanctions on Syria effective July 1, 2025. ...more
After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began...more
On June 30, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented the President’s Executive Order “Providing for the Revocation of Syria Sanctions,” (Syria EO) which removes U.S. sanctions on...more
On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more
On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more
President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more
CBP Issues Facility Requirements for Bonded Warehouses In a Cargo Systems Messaging Service (“CSMS”) message, U.S. Customs and Border Protection (“CBP”) clarified that bonded warehouses, as defined in 19 C.F.R. § 19.1, do...more
On 13 May 2025, U.S. President Donald Trump announced that his administration will start “restoring the normal relationship” with Syria’s new government and “ordering the cessation of sanctions against Syria.” While, at the...more
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more
Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more
As we head toward Valentine’s Day 2025, everywhere you look, love is all around. Washington, D.C., is no exception—the White House and government agencies seem to be proudly displaying their ardor for changing the country’s...more
In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more
Besides certain expansions on remittances in 2022, the White House, on Jan. 14, 2025, issued a statement announcing President Joe Biden's plans to relax sanctions on Cuba through a series of broad measures aimed at improving...more
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....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
With the rapid commercialization of artificial intelligence (AI) technology, the Biden administration has been grappling with its implications, including its potential impact on national security. Several departments have...more
The Final Rule formalizes a new governmental system to monitor through a notification process and, when necessary, restrict investments in China that may be viewed as a national security risk. The regulations have broad...more
October was a robust month for compliance with agency actions and guidance concerning anti-boycott, forced labor, section 301 exclusions, outbound investment, and sanctions. The International Trade Commission also voted...more
I. US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more
The Department of Commerce’s Bureau of Industry and Security (BIS) recently issued an interim final rule implementing licensing requirements for these emerging technology products for export to all foreign countries. See the...more
In line with Group of Seven (G7) efforts to disrupt the Russian military-industrial base’s reliance on foreign IT systems, in June 2024 the U.S. Department of Commerce and the Department of the Treasury jointly issued new...more