2 Gurus Talk Compliance: Episode 47 – The Chaos Edition
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
Today, April 8, 2025, the U.S. Department of Justice’s Final Rule restricting transfers of bulk sensitive personal data and U.S. government-related data becomes effective, implementing former President Biden’s Executive Order...more
On April 8, 2025, a sweeping rule issued by the US Department of Justice (DOJ) will take effect. The rule imposes restrictions—and in some cases, outright prohibitions—on US companies in connection with certain types of data...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
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 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
Florida enacted Senate Bill (SB) 264 (Chapter 2023-33, Laws of Florida) in May 2023 to limit select persons from "foreign countries of concern" from owning, having a controlling interest in or acquiring an interest in certain...more
The Florida Department of Commerce (Department) on Sept. 20, 2023, published proposed rules interpreting Florida's law limiting "foreign principals" from "foreign countries of concern" – China, Russia, Iran, North Korea,...more
Last month, Gov. Ron DeSantis (R) of Florida signed a new law that would prohibit people who are not U.S. citizens or permanent residents and whose "domicile" is in China from purchasing certain real property in the state....more
On May 8, 2023, Gov. Ron DeSantis signed into law Senate Bill 264, creating Florida Statutes sections 692.201 through 692.205, which prohibits the direct or indirect ownership of various categories of real estate by...more
The U.S. Department of Commerce (Commerce) recently announced its "apparent" need for public comment on key aspects of a mechanism that would license or preclear certain information and communications technology and services...more
Back in May 2019, the Trump Administration issued Executive Order 13873, which was meant to police the use of certain information and communications technology and services (ICTS) purchased from "foreign adversaries." Then,...more
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
n late January 2021, the U.S. Department of Commerce issued an Interim Final Rule (Interim Rule) that would empower the Department to prohibit, mitigate and unwind certain categories of transactions with certain foreign...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
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
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more
The Trump Administration has been active on the sanctions front as a means of asserting United States foreign policy and national security interests. Congress has also taken an increasingly active and direct role of late,...more
Recently, many revisions to U.S. sanction programs (both implemented and under consideration) have been the topic of much public discussion. Often, the legal status or these revisions may be difficult to determine....more