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Re-imposing sanctions on Iran, Trump discards nuclear deal

On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more

Win some, lose some: U.S. Russia sanctions developments

The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more

Export control reform 2.0

After nearly 20 years of promulgation by executive orders, bipartisan export control reform legislation has re-established a permanent statutory basis for the control of commercial and dual-use items licensed by the...more

Iran sanctions: Snapback becomes reality

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more

United States to impose new sanctions on Russia for use of nerve agent on former Russian spy

On 8 August, the U.S. Department of State announced that new sanctions would be imposed on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act). The sanctions relate to...more

BIS expands Entity List with addition of 44 Chinese parties

Export compliance continues to be complicated for companies involved in business with China. On 1 August 2018, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting...more

U.S. stays the course on re-imposing Iran sanctions

In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more

Iran sanctions relief: Easy come, easy go…the United States withdraws from Iran nuclear deal and announces intent to re-impose...

Declaring that it is “defective at its core,” on 8 May 2018, President Trump announced that the United States would withdraw from the Iran nuclear deal and begin re-imposing sanctions that were lifted pursuant to U.S....more

U.S. imposes sanctions on Russian individuals, their companies, and Russian government officials

Today, the Trump Administration designated multiple Russian targets, including several wealthy individuals and their companies, as Specially Designated Nationals (SDNs). These designations of major companies represent the...more

Potential trade war looms

As potential trade war looms, nearly 1,300 U.S.-imports may be subject to additional 25 percent tariffs under Section 301. U.S. imports from China potentially subject to additional duties include certain chemicals,...more

Artificial Intelligence and your business: A guide for navigating the legal, policy, commercial, and strategic challenges ahead

Virtually all industries are being reshaped with the use of Artificial Intelligence and advanced machine-learning. Everything from healthtech to self-driving vehicles, to education and smart homes, drones and space, social...more

Immigration newsletter - Spring 2018

Read our Spring 2018 issue of the Immigration newsletter to learn about the following topics: - Visa sanctions on Cambodia, Eritrea, Guinea, and Sierra Leone - CBP introduces policies and procedures for searching...more

A guide to NYDFS Cybersecurity Regulation's March 1 implementation deadline

It’s been almost a year since the New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect. Since that time, a series of key dates have marked the implementation of...more

In report to Congress, U.S. Administration identifies, but does not sanction, leading Russian oligarchs and senior government...

On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities. ...more

Global Magnitsky Act and Magnitsky Act Designations: same old song, or change of tune?

On December 20, 2017, President Trump issued Executive Order 13818 implementing the Global Magnitsky Act, and the Office of Foreign Assets Control (OFAC) issued the first designations responsive to this statute. ...more

Cuba update: Trump tightens travel authorizations and targets new restricted parties

On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more

U.S. releases public guidance on entities tied to Russian Defense and Intelligence sectors

On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more

Not out of the woods yet: What the lifting of Sudan sanctions means for businesses and non-profits

Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more

De-Certification and the Iran Nuclear Deal: The Beginning of the End, or Much Ado about Nothing?

Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more

President Trump Issues Proclamation that Restricts Travel to the US by Certain Nationals from Eight Countries

On Sunday, Sept. 24, 2017, President Trump signed a presidential proclamation (the Proclamation) laying out restrictions on the entry of nationals from eight countries into the United States using certain types of immigrant...more

New executive order targets Venezuela’s access to U.S. financial markets

Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more

In Shot Across the Bow, U.S. Sanctions Venezuela’s Maduro

One day after the Venezuelan government held elections for a Constituent Assembly that the United States has asserted is aimed at rewriting the national constitution, the Department of the Treasury’s Office of Foreign Assets...more

After Washington Drama, New Russia (and Iran and N. Korea) Sanctions Set to Become Law

On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3. There is some uncertainty, but the legislation is expected to be...more

UK Financial Sanctions: Extended Reporting Requirements

On 8 August 2017, the European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 (the "Regulations") will come into force. The Regulations "expand the scope of the reporting requirements set out...more

Ahead of Maduro Power Play, Trump Administration Sanctions Venezuelan Officials

Ahead of a Constituent Assembly that could re-write the Venezuelan Constitution and dissolve state institutions, the U.S. Treasury Department’s Office of Foreign Assets Control has designated 13 current and former Venezuelan...more

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