Supply chain, end use, and human rights–related sanctions, export controls, and Entity List designations target public and private entities in China.
Human rights–related designations -
The US government has...more
The regulations will enable the UK government to sanction persons “involved” in human rights abuses — potentially anywhere in the world.
On 6 July 2020, the UK Foreign Secretary announced the introduction of the Global...more
CFIUS continued to have a busy year in 2018, and CFIUS reveals first available data about the declaration process under the new Pilot Program.
On May 16, 2020, the Committee on Foreign Investment in the United States...more
The new filing fees can be as high as $300,000 for covered transactions valued at $750 million or more.
On April 27, 2020, the US Treasury Department announced in an interim rule with request for comments that the Committee...more
The penalty reflects the increasingly active approach in the UK to the enforcement of sanctions breaches.
The UK’s financial sanctions regulator, HM Treasury’s Office of Financial Sanctions Implementation (OFSI), has...more
Under the final regulations, CFIUS filings for certain transactions will be required, and CFIUS will have broader jurisdiction to review certain foreign investments.
On January 13, 2020, the US Treasury Department published...more
1/22/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Australia ,
Bureau of Industry and Security (BIS) ,
Canada ,
CFIUS ,
Corporate Counsel ,
Critical Infrastructure Sectors ,
Federal Pilot Programs ,
Final Rules ,
FIRRMA ,
Foreign Investment ,
Jurisdiction ,
NAICS ,
National Security ,
Private Equity ,
Real Estate Transactions ,
U.S. Commerce Department ,
UK
The revised policy both clarifies and expands DOJ’s prior disclosure guidance.
On December 13, 2019, the United States Department of Justice (DOJ) revised its policy regarding voluntary self-disclosures (VSDs) of...more
The number of CFIUS notices filed is growing, more cases are extending into an investigation phase, and instances of pulling and refiling CFIUS notices are increasing.
On November 22, 2019, the Committee on Foreign...more
11/27/2019
/ Acquisitions ,
Annual Reports ,
CFIUS ,
China ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Federal Pilot Programs ,
FIRRMA ,
Foreign Investment ,
Investors ,
National Security
CFIUS has offered a one-month comment period for proposed rulemaking to implement provisions of CFIUS legislation passed in August 2018.
More than a year ago, in August 2018, US President Donald Trump signed the Foreign...more
9/27/2019
/ CFIUS ,
Covered Transactions ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Export Controls ,
Federal Pilot Programs ,
FIRRMA ,
Foreign Investment ,
National Security ,
Real Estate Transactions ,
U.S. Treasury
New restrictions prohibit dealings between US persons and the Government of Venezuela.
On August 5, 2019, President Trump issued Executive Order (E.O.) 13884, entitled “Blocking the Property of the Government of...more
BIS designates Huawei Technologies Co., Ltd. and certain of its affiliates to the Entity List, restricting their ability to receive US products, software, and technology.
On May 16, 2019, the US Commerce Department’s...more
5/24/2019
/ Bureau of Industry and Security (BIS) ,
Cybersecurity ,
Economic Sanctions ,
Entity List ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
General Licenses ,
Huawei ,
Telecommunications ,
U.S. Commerce Department
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program.
On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
5/9/2019
/ Audits ,
Black & Decker ,
Chief Compliance Officers ,
Compliance ,
Corporate Counsel ,
Corporate Management ,
Economic Sanctions ,
Enforcement Actions ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training
Trump Administration breaks with precedent to allow US plaintiffs to bring “trafficking” suits under Title III of the Helms-Burton Act.
Title III of the Helms-Burton Act (the Cuban Liberty and Democratic Solidarity...more
OFAC adds PdVSA to its sanctions list and simultaneously issues general licenses temporarily allowing certain transactions and activities involving PdVSA.
On January 28, the US Treasury Department’s Office of Foreign...more
OFAC added several parties to the SDN List and simultaneously issued a General License, authorizing certain wind-down activities until January 8, 2020.
Today, the Treasury Department’s Office of Foreign Assets Control...more
Withdrawal from the Iran nuclear agreement triggers full implementation of US sanctions, including threat of “secondary” sanctions on non-US persons dealing with Iran.
As reported in the Latham Client Alert dated May 10,...more
11/6/2018
/ Economic Sanctions ,
EU ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Trump Administration
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
9/16/2017
/ Asset Freeze ,
Congressional Authority ,
Cybersecurity ,
Economic Sanctions ,
Foreign Relations ,
Human Rights ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Pipelines ,
Russia ,
SDN List ,
Secondary Sanctions ,
Terrorism Funding ,
Trump Administration
President Trump issues an Executive Order prohibiting certain transactions involving the Venezuelan government and state-owned or state-controlled entities.
Key Points:
..The Executive Order imposes new sanctions that...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions.
On Wednesday, August 2, 2017, President...more
Trump administration expected to maintain changes, but certain restrictions remain.
In the final days of his administration, President Obama announced significant changes to the US embargo against Sudan, in place since...more
Increasingly interconnected global businesses need to focus on how export controls and trade sanctions can affect their cross-border activities in unexpected ways.
For decades, the US Government has used trade...more
10/24/2014
/ Chief Compliance Officers ,
Cloud Computing ,
Cross-Border Transactions ,
E-Commerce ,
Encryption ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Mobile Devices ,
Networks ,
SaaS ,
Sanctions ,
Software ,
Software Developers ,
Technology ,
Third-Party Risk
The US and EU take coordinated action to broaden and align their Russia-related sanctions — which may evolve further depending on Ukraine peace plan progress.
On September 12, 2014, the US and the EU announced new and...more
9/16/2014
/ Asset Freeze ,
Banking Sector ,
Banks ,
Debt Financing ,
Equity Financing ,
EU ,
Export Controls ,
Russia ,
Sanctions ,
SSI List ,
Travel Ban ,
Ukraine
The European Union (EU) enacted Council Regulation (EU) No 833/2014 (the Regulation), which contains ‘Stage 3’ sanctions against Russia. These sanctions resemble – but in other ways are different – from the latest US...more
The EU’s “Stage 3” sanctions restrict exports to the Russian military, exports of certain technologies for the oil industry, and certain Russian State-owned banks’ access to EU capital markets.
New EU Measures Target...more
8/1/2014
/ Asset Freeze ,
Banks ,
Capital Markets ,
EU ,
Export Controls ,
Exports ,
Firearms ,
Oil & Gas ,
Russia ,
Russian Military Procurement ,
Sanctions ,
Ukraine