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OFAC Has Been Talking About Compliance Through Enforcement - Have You Been Listening?

Last Thursday, January 31, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued its first enforcement action of 2019, a fascinating case involving false eyelashes that teaches that virtually any...more

OFAC Designates PDVSA to Initiate End Game in Venezuela

In what was perhaps an inevitable escalation, on Monday, January 28, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed sanctions on Venezuelan state-owned oil and gas company Petróleos de...more

OFAC Delists Oligarch Companies Over Congressional Objections

On Sunday, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska, including the second-largest aluminum...more

Senior DOJ Official Discusses the Department's Renewed Focus on FARA: What Companies Need to Know

During a Tuesday event at the Center for Strategic and International Studies in Washington, D.C., Assistant Attorney General of the National Security Division John Demers highlighted the renewed focus of the Department of...more

OFAC Begins Process to Delist Oligarch Companies, Sanctions More Russian Operatives

On December 19, 2018, Treasury’s Office of Foreign Assets Control (OFAC) took two complementary actions involving U.S. sanctions related to Russia. The first was notifying Congress of the office’s intent to terminate...more

Opportunity to Comment on Emerging Technologies Subject to Future Export and Investment Restrictions

The Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM or the “Notice”) on November 19, 2018, concerning the list of “emerging and foundational technologies”...more

Iran Sanctions: Snap-Back, Part 2

Executive Summary - On November 5, 2018, the United States enacted the second of two powerful phases of the “snap-back” of Iran sanctions, re-imposing sanctions that were lifted by the United States in 2016 as a result of...more

Revised CFIUS Bill Receives Unanimous Approval in House and Senate Committees; Increases Export Controls for “Critical...

Legislation that would substantially overhaul the law governing the Committee on Foreign Investment in the United States (CFIUS) received unanimous committee approvals in the House and Senate today. The proposed legislation...more

ZTE Denial Order: Growing Tensions between the U.S. and China’s Economic Actions and Policies

Use of the U.S. Department of Commerce’s ability to block U.S. export activities may have significant consequences for one of China’s largest telecom equipment producers....more

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