On November 12, 2020, President Trump issued an Executive Order titled "Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies," which will prohibit U.S. persons from participating...more
The Situation: On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (the "HKAA"), the U.S. government's response to China's new National Security Law for Hong Kong.
The Result: The HKAA could...more
7/24/2020
/ Blocking Sanctions ,
China ,
Export Controls ,
Foreign Financial Institutions (FFI) ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
Supply Chain ,
Trump Administration ,
U.S. Treasury ,
US State Departments ,
US Trade Policies
The Situation: A U.S. District Court vacated a $2 million penalty imposed by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") against Exxon Mobil Corporation ("Exxon") because OFAC failed to...more
2/20/2020
/ Due Process ,
Executive Orders ,
Exxon Mobil ,
Fair Notice ,
Fifth Amendment ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Agenda ,
Sanction Violations ,
SDN List ,
Trump Administration ,
Vacated
Companies in the banking/financial, energy, logistics, and shipping sectors should assess their operations to mitigate sanctions compliance risks.
On Monday, April 22, 2019, the Trump Administration announced that, in the...more
The Situation: The U.S. government imposed initial sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. The sanctions relate to the March 2018 attempted assassination of...more
The Situation: Ever since President Trump launched major trade initiatives last year, there has been considerable uncertainty about how the administration would proceed. Recent developments have clarified the intentions of...more
6/21/2018
/ China ,
Foreign Acquisitions ,
Imports ,
NAFTA ,
Risk Mitigation ,
Section 232 ,
Section 301 ,
Semiconductors ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
The Situation: On Tuesday, May 8, 2018, President Trump announced that the United States has withdrawn from the Iran Nuclear Deal and will fully reimpose its suspended sanctions targeting Iran.
The Result: All currently...more
5/14/2018
/ Economic Sanctions ,
Exporters ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
National Security ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
TSRA
On May 8, 2018, President Trump announced that the United States would cease participating in the Joint Comprehensive Plan of Action ("JCPOA"), commonly known as the Iran Deal. This will reimpose, by no later than November 5,...more
5/10/2018
/ Economic Sanctions ,
EU ,
Export Controls ,
Foreign Policy ,
General Licenses ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
The Situation: The Trump Administration has imposed sanctions against a number of high-profile Russian individuals and entities by adding them to the Specially Designated Nationals and Blocked Persons ("SDN") List.
The...more
4/12/2018
/ Blocked Person ,
CAATSA ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
General Licenses ,
Government Officials ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
State-Owned Enterprises ,
Trump Administration ,
U.S. Treasury
The Situation: Regulations implementing tightened U.S. policy towards engagement with Cuba have rolled back a number of Obama-era initiatives and are effective immediately.
The Result: Provisions that encourage Cuban...more
12/1/2017
/ Cuba ,
Cuba Restricted List ,
Cuban Assets Control Regulations (CACR) ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Policy ,
General Licenses ,
Presidential Memorandum ,
Private Sector ,
Trade Relations ,
Travel Restrictions ,
Trump Administration
On Friday, October 13, 2017, President Trump announced that he would not certify that the suspension of sanctions pursuant to the Joint Comprehensive Plan of Action ("JCPOA") (commonly known as the Iran Nuclear Deal) is...more
In Short -
The Situation: Over the past several months, North Korea has engaged in several activities, particularly relating to missile and nuclear testing, that violate several United Nations resolutions and that...more
10/3/2017
/ Aircraft ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Exports ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Imports ,
National Security ,
North Korea ,
Nuclear Weapons ,
SDN List ,
Secondary Sanctions ,
Third Country Entities (TCEs) ,
Trade Restrictions ,
Trump Administration ,
Vessels
On August 24, 2017, President Donald Trump issued an Executive Order imposing new sanctions intended to restrict financing connected to the Government of Venezuela. These sanctions supplement existing sanctions imposed by the...more
9/5/2017
/ Bonds ,
Citgo ,
Debt-Equity ,
Dividends ,
Economic Sanctions ,
Executive Orders ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration ,
Venezuela
On August 2, 2017, President Trump signed the "Countering America's Adversaries Through Sanctions Act" ("Act") into law. The Act, which codifies and strengthens sanctions against Russia and expands sanctions against Iran and...more
8/8/2017
/ Congressional Override ,
Economic Sanctions ,
Energy Sector ,
Exports ,
Financial Services Industry ,
Foreign Relations ,
Imports ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
SSI List ,
State-Owned Enterprises ,
Trump Administration
On July 11, 2017, President Trump issued an executive order that postpones any decision regarding whether to terminate the comprehensive sanctions regime against Sudan for an additional three months—until October 12, 2017....more
In our December 2016 Commentary on the "Government Contracts Ramifications of the Trump Election" and our January 2017 update, we predicted that the Trump Administration would seek to strengthen domestic preferences in...more
5/4/2017
/ Buy America ,
Buy American Act ,
Domestic Hiring Policy ,
Executive Orders ,
Federal Contractors ,
Public Interest Waivers ,
Public Procurement Policies ,
Steel Industry ,
Subcontractors ,
Supply Chain ,
Trump Administration ,
USTR ,
WTO