On a bizarre day for sanctions that saw President Trump seemingly take action related to North Korea via tweet – revoke recent measures? scuttle pending ones? – the U.S. Treasury Department’s Office of Foreign Assets Control...more
In another indication of the U.S. Department of Justice’s increased focus on the Foreign Agents Registration Act (FARA), Assistant Attorney General John Demers announced that the Department is overhauling its FARA enforcement...more
UPDATE: Two days after we issued our Top 20 sanctions compliance lessons from recent OFAC enforcement cases, OFAC issued an unprecedented enforcement one-two punch. On February 7, 2019, OFAC settled an enforcement case with...more
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
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
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
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
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
The US Export Control Reform Act of 2018 (ECRA) requires the US Department of Commerce's Bureau of Industrial Security (BIS) to develop a corresponding list of “emerging and basic technologies”. To this end, BIS issued the...more
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
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more
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
As many life sciences companies and investors are aware, the U.S. Department of the Treasury (“Treasury”) recently announced a new “pilot program” for the Committee on Foreign Investment in the United States (“CFIUS”)...more
The Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”), which became law on August 13, 2018, effected sweeping change to the authority and processes of the Committee on Foreign Investment in the United States...more
On August 6, 2018, President Trump signed an executive order (“New Iran E.O.”) directing the Secretaries of State and the Treasury to re-impose sweeping sanctions on Iran, effecting the policy announced on May 8, 2018, to...more
On August 13, 2018, President Trump signed into law the Foreign Investment Review Risk Modernization Act of 2018 (“FIRRMA”) as part of the John S. McCain National Defense Authorization Act for 2019 (“2019 NDAA”). FIRRMA is...more
BELTWAY -
The Wayback Machine -
Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more
6/8/2018
/ Arbitration ,
Auto Lease ,
Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Fair Lending ,
FDCPA ,
FFIEC ,
FinTech ,
GAO ,
General Data Protection Regulation (GDPR) ,
HMDA ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
TCPA
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
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
On November 8, bipartisan lawmakers in both houses of the United States and the United Democrats proposed a new act aiming to make major revisions to the current review of the laws applicable to the U.S. Foreign Investment...more
Recently proposed legislation would substantially overhaul current law governing the Committee on Foreign Investment in the United States (CFIUS) by dramatically expanding CFIUS’ authorities and calling for CFIUS to take...more
On November 8, 2017, bipartisan coalitions in both the House and the Senate announced new legislation that would substantially overhaul current law governing the Committee on Foreign Investment in the United States (CFIUS)...more
The U.S. Supreme Court on Oct. 16, 2017, announced it had granted the government’s petition for certiorari in United States v. Microsoft and will hear a case this Term that could have lasting implications for how technology...more
Last week, the Department of Justice (DOJ) announced a new policy that significantly restricts its practice of seeking non-disclosure orders under the Stored Communication Act (SCA), 18 U.S.C. § 2705(b), in connection with...more
Arrest of a Chinese National on Hacking Charges Illustrates How U.S. Tactics Are Changing to Meet the New Cyber Threat -
In August, Yu Pingan, a Chinese national, was arrested on charges that he conspired to acquire and...more
10/23/2017
/ Carpenter v US ,
China ,
Critical Infrastructure Sectors ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Foreign Agents ,
Fourth Amendment ,
Hackers ,
Iran ,
North Korea ,
Russia ,
Sanctions ,
SCOTUS ,
Surveillance ,
Wikimedia