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Summary of Sanctions Imposed on Russia This Week (March 4, 2022)

Over the last two weeks, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. ...more

Summary of the Wide-Ranging Sanctions Imposed on Russia This Week

This week, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia in response to Russia’s invasion of Ukraine. We expect Western countries to...more

Commerce Department Issues New Export Controls on Russia in Response to the Invasion of Ukraine

As part of a package of new sanctions on Russia that are effective February 24, 2022, the United States imposed a series of significant new export control measures on exports of many products, software and technology to...more

European Union Announces First Round of Sanctions on Russia: Banks, Sovereign Debt, Elites, & DNR/LNR Trading Ban  

Today, the European Union announced that it approved new sanctions on Russia in response to the situation in Ukraine. The array of measures to be imposed by the EU mirror elements of the sanctions imposed over the last few...more

U.S. Authorizes Broader Sanctions on Belarus, Targeting Government and Key Economic Sectors

On August 9, 2021, President Biden issued an Executive Order (E.O.) authorizing the imposition of additional sanctions on the Government of Belarus and a number of key sectors of the Belarusian economy in coordination with...more

New Executive Order Targets Investments in Chinese Surveillance and Military Companies

Today, President Biden issued an Executive Order expanding U.S. restrictions on dealings in the publicly traded securities of Chinese companies. Today’s move amends Executive Order 13959 to prohibit U.S. persons from buying...more

How New CFIUS Rules on Critical Technology Affect CFIUS Filing Strategy

The Department of Treasury’s office that administers reviews of foreign investments in U.S. companies is changing how it identifies critical technology businesses and related technologies that require mandatory review during...more

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

President Issues Executive Orders Targeting TikTok and WeChat

Last Thursday, the President issued two executive orders (“E.O.s”) targeting social media applications TikTok (and its parent company, ByteDance) and WeChat (and its parent company, Tencent Holdings). The E.O.s direct the...more

COVID-19 Accountability Act  – New Potential Sanctions on China

Earlier this week, the COVID-19 Accountability Act was introduced in the Senate and the House by Rep. Senator Lindsey Graham and Rep. Doug Collins respectively. While the text of the draft legislation is not yet available, a...more

U.S. Treasury Lifts Sanctions on Nynas AB

On May 12, 2020, the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) announced that U.S. persons no longer need OFAC authorization to engage in dealings with Nynas AB, provided such activities do not involve blocked...more

U.S. State Department Announces Temporary ITAR Provisions In Response to COVID-19

The Department of State’s Office of Defense Trade Controls Policy announced that they are temporarily suspending, modifying, and excepting certain International Traffic in Arms Regulations (ITAR) requirements in an effort to...more

Attention Exporters of PPE – New Exemptions from FEMA Export Restrictions

Our previous blog post listed the specific types of PPE respirators, masks, and gloves restricted for export from the U.S. on April 10, 2020 by the Federal Emergency Management Agency (FEMA) in response to the COVID-19...more

Implications for Suppliers – Chevron Ordered to Wind Down Venezuela Business By December 1, 2020 (with Limited Wind-Down...

On April 22, 2020, President Trump ordered Chevron to “wind down” its business in Venezuela by December 1, 2020. This will have a significant impact on companies that supply Chevron with equipment used for oil and gas...more

FEMA Issues New Rule Requiring Approval for Exports of Certain Personal Protective Equipment

On April 10, 2020, the Federal Emergency Management Agency (FEMA) issued a temporary final rule (TFR), pursuant to the Defense Protection Act (DPA) and related authorities, to require explicit approval for exports of certain...more

COVID-19 – Four Key International Trade Compliance Considerations

Even as companies make rapid changes to respond to business challenges posed by the COVID-19 pandemic, executives and compliance team leaders must protect their company and employees by continuing to comply with critical U.S....more

U.S. Proposes Framework For Transition And Lifting Of Venezuela Sanctions

Elliott Abrams, the U.S. Special Representative for Venezuela, announced a plan to lift sanctions on Venezuela should the Maduro regime step aside to permit a transitional government to be elected until full elections can...more

Do Manufacturers Have to Report All Iranian Sales Inquiries to OFAC or Only Those They Have Formally Rejected? 

Treasury Issues New Guidance Regarding June 21, 2019 Amendment to the Reporting, Procedures, and Penalties Regulations (“RPPR”) - In late February, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

CFIUS to Cover More Foreign Investments in U.S. Companies

Companies outside the U.S. contemplating purchases of U.S. business (and potential U.S. acquisition targets) are continuing to parse the Department of the Treasury’s two proposed regulations continuing implementation of the...more

New Sanctions on Venezuela’s National Oil Company, PDVSA

Yesterday, the Office of Foreign Assets Control (“OFAC”) listed Petroleos de Venezuela, S.A. (“PdVSA”) as a Specially Designated National (“SDN”) pursuant to its authority under Executive Order 13850. As a result of the...more

Preparing for the Worst:  Licenses Needed for UK Export of Dual Use Items

It has always been a possibility that the United Kingdom would crash out of the European Union on 30 March 2019 but “no deal” preparation is now highly recommended by both sides. For organisations that export dual use items,...more

8/29/2018  /  Dual Use Goods , EU , Exports , Military Goods , Software , UK

BIS Proposed Expansion of Export Controls of Spraying and Fogging Systems Could Affect Agriculture Industry and Spray Equipment...

Earlier this week, the Bureau of Industry and Security (“BIS”) published a request for public comment regarding a proposed expansion of export controls under the Export Administration Regulations (“EAR”) for certain spraying...more

Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA)

After months of negotiation, Congress recently passed, and the president is expected to sign, the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”).[1] FIRRMA updates the national security review of inbound...more

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

The United States will Withdraw from the Iran Nuclear Deal and Fully Re-impose Nuclear Sanctions on Iran Within 180 Days

President Trump announced that the United States will exit the multilateral Iran nuclear deal and fully re-impose sanctions on Iran. After the announcement, the Office of Foreign Assets Control (OFAC), the agency responsible...more

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