News & Analysis as of

Iran

Butler Snow LLP

Proposed Rule Published Restricting Data Sharing with China, Russia, Iran, North Korea, Cuba, and Venezuela

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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

Ballard Spahr LLP

Halkbank Faces Prosecution: U.S. Court of Appeals Denies Sovereign Immunity

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On October 22, 2024, the U.S. Court of Appeals for the Second Circuit ruled that Türkiye Halk Bankası A.Ş. (“Halkbank”), owned by the Republic of Turkey, can be prosecuted for allegedly helping Iran evade U.S. sanctions and...more

Baker Botts L.L.P.

House of Representatives Passes BIOSECURE Act

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On September 9, 2024, the House of Representatives passed H.R. 8333, the BIOSECURE Act (the “House Bill”). The text of the passed House bill was unamended from the version approved by the House Committee on Oversight and...more

The Volkov Law Group

OFAC’s Stated Concern About Foreign Companies and Domestic Sanctions Compliance and Post-Acquisition Compliance (Party IV of IV)

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Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more

Locke Lord LLP

OFAC Issues Warning to Financial ‎Institutions & Insurers That ‎Provide Maritime Services in the ‎Mediterranean, Red Sea and...

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Iran and Syria Sanctions and Embargos On September 11, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued updated guidance to remind maritime support service providers that the...more

Wiley Rein LLP

Senators Look to Close Prominent FARA Registration Exemptions by Introducing STRATEGIC Act

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On September 19, a group of Republican Senators led by Foreign Relations Committee Ranking Member Jim Risch (R-ID) introduced the STRATEGIC Act of 2024 to combat Chinese Communist Party (CCP) influence within the United...more

King & Spalding

Federal Agencies Issue Warning Regarding Iran-Based Cyber Security Threats to U.S. Healthcare Entities

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On August 28, 2024, the U.S. Cybersecurity & Infrastructure Security Agency (CISA), together with the FBI and Department of Defense Cyber Crime Center, issued an advisory to U.S. organizations, including healthcare...more

Husch Blackwell LLP

BIS Issues New Guidance to Combat Russia Diversion Risks and Highlights Recent Enforcement Actions

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Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...more

A&O Shearman

Sanctions and export controls expand further - Update

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In October, the U.S. Commerce Department unveiled new rules to tighten further a sweeping set of export controls first introduced a year previously, reducing the types of semiconductor manufacturing equipment and advanced...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - August 2024 - New Presidential Proclamations – Section 232 Duties on Certain Steel and...

On July 10, 2024, the President issued two Presidential Proclamations related to the imposition of Section 232 duties on certain steel and aluminum products from Mexico. The first establishes a “melt and pour” requirement...more

Fenwick & West LLP

Commerce Department Expands Export Jurisdiction for Foreign-Made Items to Iran: Foreign Direct Product Rule Update

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On July 24, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) announced amendments to the U.S. Export Administration Regulations (EAR), expanding the reach of U.S. export jurisdiction over certain...more

Paul Hastings LLP

Statute of Limitations for IEEPA and TWEA Violations Extended to 10 Years, and Additional Sanctions Developments

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Recent legislation, H.R. 815, the National Security Supplemental (“the Act”) – further explained by guidance issued by the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC”) on July 22, 2024 – has...more

BakerHostetler

The Protecting Americans’ Data from Foreign Adversaries Act - What Digital Advertisers, Publishers and Ad Platforms Need To Know

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The Protecting Americans’ Data from Foreign Adversaries Act (PADFA or the Act) was signed into law by President Joe Biden on April 24 as part of a larger foreign aid appropriations bill. Although other portions of the...more

Foley Hoag LLP

Developments in U.S. International Trade Laws Since the Start of 2023 and What to Expect for the Rest of 2024

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Throughout 2023 and early 2024, we continue to witness deepening geopolitical and economic divides globally. The U.S. and its allies (most significantly the EU and the G7), spurred on by Russia’s war in Ukraine, continue to...more

Whiteford

Client Alert: New Laws Prohibit Certain Data Transfers to China, Russia, Iran, and other Foreign Adversaries of the U.S.

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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

Eversheds Sutherland (US) LLP

National Security Act of 2024 extends statute of limitations for sanctions violations to 10 years

The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran - The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more

Venable LLP

Data Restrictions in the 21st Century Peace through Strength Act

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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

Nelson Hardiman, LLP

Hacking and Healing: Nation-States, Cyber Attacks, and Healthcare Law

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Modern warfare is no longer restricted to physical battlefields and professional military. Countries like North Korea and Russia have few qualms about using cyberspace to reach well beyond their physical borders to target...more

The Volkov Law Group

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

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OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no...more

Alston & Bird

Look Ahead to the Week of April 15: Will Aid for Israel Pass?

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Look Ahead to the Week of April 15: Will Aid for Israel Pass? Both the Senate and House are in session this week. Over the weekend, Iran launched a coordinated attack on Israel in response to an Israeli airstrike on Iran’s...more

Flaster Greenberg PC

Can Iran Survive War with Israel?

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Since Israel killed Iran Revolutionary Guard Commander General Mohammed Reza Zahedi and six others in Damascus, Syria on April 2, Iran has sworn that it will retaliate harshly against Israel. Israeli soldiers have had their...more

BakerHostetler

The Weekly Hill Update - April 2024

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Below is this week’s congressional update by BakerHostetler’s Federal Policy team. We’ll continue to post in weeks when both chambers of Congress are in session....more

American Conference Institute (ACI)

[Event] 23rd Annual Canadian Forum on Anti-Money Laundering and Financial Crime - June 5th - 6th, Toronto, Ontario, Canada

Hosted by the Canadian Institute, the 23rd Annual Canadian Forum on Anti-Money Laundering and Financial Crime returns for another exciting year. The event features carefully curated programming providing practical guidance...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – February 2024 Update

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February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more

Goodwin

US Government Moves to Regulate Cross-Border Transactions Involving Sensitive Data

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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

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