E.O. 14032 signals that the Biden Administration will continue to restrict U.S. investments into China’s defense and surveillance technology sectors.
The prior Administration’s November 2020 Executive Order (E.O.) 13959...more
U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 17, 2021, military coup in Myanmar (also known as Burma). Over the past month, the United States...more
On April 15, 2021, the U.S. Government announced broad new sanctions authorities that can be used to target Russia and implemented limitations on dealings in Russian sovereign debt. These measures were imposed pursuant to a...more
On 22 March 2021, the EU added 11 Burmese officials responsible for last month’s military coup in Myanmar to its sanctions list. The designations are made in response to “the illegitimate over-throwing of the...more
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against...more
On March 2, 2021, the U.S. Department of the Treasury’s Office of Asset Controls (OFAC) imposed sanctions on two key militant leaders of the Iranian-backed Ansarallah, also known as the Houthis. OFAC sanctions target Mansur...more
On February 18, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) entered into a settlement of $507,375 with BitPay, Inc. (BitPay) for violations of multiple U.S. sanctions programs. According to...more
In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect...more
Summary of the EO -
On January 12, 2021, former President Trump issued an EO on Promoting Small Modular Reactors for National Defense and Space Exploration. The EO directs the Department of Energy (DOE), Department of...more
2/4/2021
/ Aerospace ,
Biden Administration ,
Department of Defense (DOD) ,
Department of Energy (DOE) ,
Energy Sector ,
Executive Orders ,
NASA ,
New Legislation ,
Nuclear Power ,
Technology Sector ,
Trump Administration
On January 13, 2021, U.S. Customs and Border Protection (CBP) issued a withhold-release order (WRO) on all cotton and tomato products from China’s Xinjiang Uyghur Autonomous Region (XUAR) based on information that reasonably...more
On January 10, 2021, then Secretary of State Mike Pompeo designated Ansarallah, an armed militia in Yemen backed by Iran also known as the “Houthis,” as a Foreign Terrorist Organization (FTO) and as Specially Designated...more
On January 19, 2021, the Commerce Department issued an interim final rule to implement the Executive Order on Securing the Information and Communications Technology and Services Supply Chain (E.O. 13873), which was issued on...more
One portion of the National Defense Authorization Act creates a federal beneficial ownership registry, with reporting requirements for corporations, LLCs and “other similar entities.”
The Corporate Transparency Act creates...more
1/7/2021
/ Anti-Money Laundering ,
Compliance ,
Control Test ,
Disclosure Requirements ,
FinCEN ,
Fund Sponsors ,
Investors ,
NDAA ,
Real Estate Development ,
Reporting Requirements ,
Standard Operating Procedures ,
Transparency
New federal requirements in the annual national defense budget reauthorization effectively will end anonymous U.S. shell companies by requiring businesses to disclose 25 percent owners and control persons to a newly created...more
1/6/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Drug Trafficking ,
Financial Institutions ,
FinCEN ,
Fraud ,
Guidance Update ,
Human Trafficking ,
Law Enforcement ,
Patriot Act ,
Penalties ,
Regulatory Requirements ,
Reporting Requirements ,
Shell Corporations ,
Terrorist Acts ,
U.S. Treasury ,
Virtual Currency ,
Whistleblowers
On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration...more
On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense...more
On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that...more
On November 12, 2020, President Trump issued an Executive Order (E.O.) prohibiting U.S. persons from engaging in any transaction (defined as a “purchase for value”) of publicly traded securities, or transacting in financial...more
Over the course of the Obama and Trump administrations, U.S. officials have found new ways to incorporate human rights concerns into sanctions and export control policies. Recent announcements by the Commerce and State...more
Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in...more
BitMEX, a Seychelles-based centralized exchange for trading derivatives on bitcoin, ether and litecoin, and certain of its executives have been charged with a number of violations under the U.S. Commodity Exchange Act (CEA),...more
10/8/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
CFTC ,
Commodity Exchange Act (CEA) ,
Department of Justice (DOJ) ,
Digital Assets ,
Due Diligence ,
Ether ,
Futures Commission Merchants (FCMs) ,
Geo-Blocking ,
SEFs ,
Trading Platforms ,
U.S. Customs
On September 14, 2020, U.S. Customs and Border Protection (CBP) issued five Withhold Release Orders (WROs) for a range of goods produced in the Xinjiang region of China. Under 19 U.S.C. § 1307, CBP can initiate enforcement...more
On September 18, 2020, the U.S. Commerce Department published two rules defining the scope of prohibited transactions related to the mobile applications, WeChat and TikTok. The scope of prohibited transactions clarified the...more
On August 11, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new guidance document, the Sudan Program and Darfur Sanctions Guidance (“Sudan Guidance”), which clarifies the current...more
The Department of Commerce (the Department) has proposed to modify its regulations under Part 351 of Title 19 to improve administration and enforcement of the antidumping duty (AD) and countervailing duty (CVD) laws....more