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DOJ Releases New Key Guidance on Its Data Security Program (DSP)

On April 11, 2025, the National Security Division (NSD) of the Department of Justice issued a press release (Press Release) that outlines its approach to implementing and enforcing the DOJ’s recent final rule on “Preventing...more

Trump Administration’s America First Investment Policy to Bring Changes to CFIUS and Outbound Investment Reviews

Below is a summary of some of the measures identified in the Policy, and some suggestions for what foreign and domestic investors should be considering as this goes into effect....more

President Trump Imposes Additional Tariffs on Steel and Aluminum

The breaking tariff news continues — this time with a focus on steel and aluminum imports. On Monday, February 10, 2025, President Trump issued an executive order expanding his 2018 Section 232 national security tariffs...more

President Trump Defers Tariffs on Canada and Mexico, Imposes Additional Tariffs on China, and China Responds With Countermeasures

Deferral of Tariffs on Imports From Canada and Mexico - The previously announced tariffs against goods from Canada and Mexico have been paused for one month, with both Canada and Mexico agreeing to take, respectively,...more

Treasury’s Outbound Investment Security Program Focusing on China Is in Effect (for Now)

Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more

U.S. Department of Commerce Issues Interim Final Rule Implementing Its Framework for Artificial Intelligence Diffusion

On January 13, 2025, BIS issued an interim rule amending the EAR to, among other things, impose a new control on certain advanced AI model weights for certain advanced closed-weight dual-use AI models, and revise controls on...more

U.S. Commerce Department Strengthens Export Controls to Restrict China’s Semiconductor Production

Background - On December 2, 2024, BIS announced two new rules under the EAR targeting the PRC’s ability to produce “advanced-node” semiconductors, including advanced-node integrated circuits (ICs), which can be used in...more

Trade Secrets to Be Subject to Export Controls Under House-Passed Bill

On September 9, 2024, the U.S. House of Representatives passed legislation that would expand the scope of the Export Control Reform Act of 2018 (ECRA) to include the protection of trade secrets. The one-sentence bill, which...more

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

Additional Export Restrictions to Russia and Belarus: BIS Announces Additional Export Sanctions Against Russia and Belarus and...

On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more

New License Exception for Medical Devices Destined for Russia, Belarus and Certain Regions of Ukraine: BIS Announces a Final Rule...

On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) announced the issuance of a final rule that amends the Russian and Belarus Sanctions under the Export Administration Regulations (EAR) to...more

Biden Administration Aims to Address National Security Risks to the U.S. Auto Industry

On February 29, 2024, the U.S. Department of Commerce announced that it is launching an investigation into the national security risks posed by Chinese-manufactured technology embedded in connected vehicles (CVs). Such...more

Congress’s Emerging Vision of an ‘Outbound Investment Screening Mechanism’

Ready or Not: Momentum Continues to Build in Washington for Outbound Investment Screening Mechanism - On May 9, 2023, a bipartisan group of U.S. House members introduced the National Critical Capabilities Defense Act of...more

G-7 Summit Kicks Off With New Russian Sanctions

As the 49th Group of Seven (G7) Summit gets underway in Japan, the United States, in coordination with several other G7 members, marked the occasion to announce sweeping new sanctions and export controls aimed at “further...more

One-Year Anniversary of Russian Invasion of Ukraine Brings New Sanctions, Export Controls and Tariffs

On February 24, 2023, the White House marked the one-year anniversary of the Russian invasion of Ukraine by announcing a sweeping package of new sanctions, export controls and tariffs aimed at “holding Russia accountable for...more

Return to Sender: New DOJ/Commerce Strike Force Aims to Broaden Export Control Enforcement and Prosecutions

On February 16, 2023, the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce announced the creation of the “Disruptive Technology Strike Force” — a multi-agency, multi-geographical effort to ratchet up the...more

FinCEN Warns of Potential Sanction Evasion by Russian Entities Involved in U.S. Commercial Property Investments

On January 25, 2023, the Financial Crimes Enforcement Network (FinCEN) published an alert to financial institutions warning of the heightened risk of investment in commercial real estate by sanctioned Russian elites,...more

BIS Announces New Export Controls on Advance Computing and Semiconductor Manufacturing, Including Revisions to Foreign Direct...

Summary of Key Points: Although this rule is aimed at the semiconductor and supercomputer industries, it will have a much broader effect on U.S. and ex-U.S. manufacturing, including even certain EAR99 goods manufactured...more

Raising the Bar? Biden Administration Adds New Evaluation Criteria to CFIUS Reviews

On September 15, 2022, President Biden signed an Executive Order (EO) directing the Committee on Foreign Investment in the United States (CFIUS or the Committee) to specifically consider certain factors when reviewing the...more

Russian Sanctions/Export Controls Update: OFAC and BIS Expand Restrictions

Seven months into Russia’s invasion of Ukraine, the United States continues to expand and develop its Russia sanctions program. Most recently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more

CBP and DHS Issue Guidance on Implementation of the Uyghur Forced Labor Prevention Act

The week of June 12, 2022, the Department of Homeland Security (DHS) and U.S. Customs and Border Protection (CBP) released two important guidance documents to prepare the public for the implementation of the Uyghur Forced...more

USTR Sets the Stage for its Reassessment of Section 301 Tariffs on Chinese-Origin Goods

In a highly anticipated development, on May 3, 2022, the United States Trade Representative (USTR) announced the initiation of a statutory process whereby USTR is expected to conduct a reassessment of the existing Section 301...more

5/4/2022  /  Importers , Imports , Section 301 , Tariffs , USTR

Russian Sanctions/Export Controls Update: U.S.-European Sanctions/Export Control Measures Continue to Mount

The Russian invasion of Ukraine is continuing to prompt escalating sanctions and export controls on both sides of the Atlantic. Our team breaks down the latest measures coming out of the European Union, the United Kingdom and...more

Russian Sanctions/Export Controls Update: New Targets Identified

As the Russian invasion of Ukraine continues to escalate, the U.S. and its allies are still implementing (and considering) additional sanctions and export control measures aimed at isolating Russia’s economy and weakening...more

Russian Sanctions/Export Controls Update: The Second Tranche

In the immediate wake of Russia’s full-scale invasion of Ukraine, President Biden announced a package of sweeping economic sanctions and export control measures intended to “impose severe costs on the Russian economy, both...more

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