On her first day in office, Attorney General Pam Bondi published several memorandums laying out the reprioritization of US Department of Justice (DOJ) efforts and funding, including the memorandum General Policy Regarding...more
President Donald Trump on February 21, 2025 issued a National Security Presidential Memorandum titled the America First Investment Policy to provide guidance to executive departments in their review and decision-making with...more
The US Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24) authorizing certain transactions with the new Syrian government and easing some transactions related to energy and personal remittances....more
Marking what appears to be a reversal of previous policy, the Office of Foreign Assets Control (OFAC) determined that US persons can, subject to certain limitations, include sanctioned persons as speakers at overseas...more
In a ruling eagerly awaited by the cryptocurrency industry, the US Court of Appeals for the Fifth Circuit held that immutable smart contracts on the Tornado Cash crypto-transaction software protocol are not “property” subject...more
The US Office of Foreign Assets Control recently amended its insurance-related FAQ and issued two new FAQs. This focus on insurance-related guidance comes at the same time as an enforcement action targeting an insurer that...more
Though unutilized for the first 18 months of its life, a recent presidential delegation suggests that the administration may be ready to wield the sanctions authority found in the Protecting American Intellectual Property Act...more
OFAC’s new FAQ 1097, issued October 10, warns US investors of the need to block securities held at Russia’s National Settlement Depository (NSD), even if the securities or the issuer is not sanctioned. Even if the security is...more
The US Office of Foreign Assets Control first issued the Syrian Sanctions on April 5, 2005, implementing Executive Order 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria.” On...more
The Biden administration suspended certain sanctions on the Government of Venezuela, including some impacting Petróleos de Venezuela S.A. (PdVSA), on October 18, 2023. This significant, albeit currently temporary, change in...more
The US government’s multibranch effort to implement a new regulatory regime designed to regulate outbound investments based on national security concerns moved forward with the White House’s August 9, 2023 Executive Order, EO...more
The passage of the Protecting American Intellectual Property Act of 2022, 35 USC § 1709 (PAIPA), earlier this year underscored Congress’s continued aggressive approach to protecting domestic trade secrets from...more
Congress recently passed and sent to the president the Protecting American Intellectual Property Act of 2022. The act mandates sanctions on entities and individuals identified by the executive branch as having committed...more
The US Department of the Treasury’s Office of Foreign Assets Control issued a Determination on December 5 implementing a $60 “price cap” on Russian crude oil, pursuant to which US persons are authorized to provide otherwise...more
Based on the evolving military operations of the Russian Federation in Ukraine, the United States has imposed additional sanctions on the Russian Federation, Russian leadership, and various financial institutions and...more
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the...more