Eric McClafferty

Kelley Drye & Warren LLP

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CFIUS Issues New Enforcement and Penalty Guidance

On October 20, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued a press release laying out new guidance to provide clarity about how the Committee assesses violations of the laws and...more

10/21/2022 / CFIUS , Corporate Counsel , Foreign Investment , National Security , Penalties

New Export Control Test for CFIUS Mandatory Critical Technology Filings

On September 14, 2020, the U.S. Department of Treasury, as Chair of the Committee on Foreign Investment in the United States (CFIUS), published final regulations changing the mandatory CFIUS declaration requirements for...more

9/17/2020 / CFIUS , Corporate Counsel , Export Controls , Exports , Foreign Investment , Technology Sector

Between a Rock and a Hard Place: EU & Russia Move Forward with “Blocking Statutes” in Response to U.S. Exit from Iran Nuclear Deal

Sanctions blocking statutes being prepared by the European Commission (EC) and Russia could put companies in the middle of conflicting legal requirements, raising difficult and complex sanctions compliance decisions. ...more

5/21/2018 / Corporate Counsel , Economic Sanctions , EU , Iran Sanctions , Joint Comprehensive Plan of Action (JCPOA) , Nuclear Weapons , Office of Foreign Assets Control (OFAC) , Russia

Epsilon Case Highlights the Need for Sanctions Due Diligence on Resellers

As global companies begin to reenter the Iranian market, a decision issued by the U.S. District Court for the District of Columbia is an important reminder that resellers and distributors can generate liability for U.S....more

3/31/2016 / Corporate Counsel , Due Diligence , Export Controls , Exports , Iran , Iran Sanctions , ITSR , Office of Foreign Assets Control (OFAC) , Resales Agreements , Sales & Distribution Agreements , United Arab Emirates (UAE)

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