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President Trump Places His Early Mark on Export Controls

Howard Lutnick has been confirmed as Secretary of Commerce, while Jeffrey Kessler has been nominated for Under Secretary for Industry and Security. Both have more experience with trade policy and tariffs than with export...more

President Trump Changes National Security Council to Align with New Priorities

On January 20, 2025, President Trump signed the National Security Presidential Memorandum (NSPM-1), which lays out the framework for how the National Security Council (NSC) will be organized under his administration. The...more

Commerce Issues Proposed Rule on “Malicious Cyber-Enabled Activities” and Artificial Intelligence

On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule (the Proposed Rule) that would impose significant know-your-customer (KYC), monitoring and reporting obligations...more

Biden Administration Issues New Sanctions and Export Controls to Respond to Coup in Burma

Key Points - On February 11, 2021, in the first deployment of sanctions since assuming office, President Biden issued EO 14014, authorizing sanctions against members of the Burmese military and related parties responsible...more

President Trump Declares National Emergency to Secure the Information and Communications Technology and Services Supply Chain

• On May 15, 2019, President Trump issued a long-awaited E.O. designed to curtail the use of telecommunications items and services from certain countries and persons in U.S. networks. The E.O. does not impose immediate...more

OFAC Sanctions Venezuelan State-Owned Energy Company PdVSA, Releases New General Licenses and FAQs for Venezuela Sanctions Regime

• On January 28, 2019, OFAC added the Venezuelan state-owned oil and natural gas company PdVSA to its SDN List. • As a result, U.S. persons are generally prohibited from engaging in transactions with PdVSA and entities that...more

Trump Administration Sanctions Chinese Entity and its Director in First Imposition of Secondary Sanctions under Section 231 of...

• On September 20, 2018, for the first time, the Trump administration imposed sanctions on a non-U.S. entity and its director for engaging in “significant transactions” with a Russian defense sector company included on the...more

President Trump Issues New Iran Executive Order and Reimposes First Set of Sanctions Following JCPOA Withdrawal

• On August 6, 2018, following President Trump’s decision to withdraw the United States from the JCPOA, the U.S. government announced the reimposition of sanctions on Iran’s automotive sector, its trade in gold and precious...more

United States Imposes New Sanctions Restricting Transactions with the Government of Venezuela

• On May 21, 2018, the Trump administration imposed new sanctions on the Government of Venezuela in response to the reelection of President Maduro and the “deepening humanitarian and public health crisis” fueled by the Maduro...more

OFAC Sanctions Leading Russian Businessmen, Government Officials and Companies

• On April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) placed seven prominent Russian businessmen, 12 companies, 17 senior Russian government officials, and a state-owned Russian...more

Trump Administration Lifts U.S. Sanctions on Sudan; Important Limitations Remain

Based on certain State Department findings, effective October 12, 2017, long-standing U.S. sanctions on the Republic of Sudan administered by OFAC under the Sudan Sanctions Regulations will be terminated, and U.S. persons...more

Implementing CAATSA - OFAC Issues Amended Russian-Related Sectoral Sanctions Under Directives 1 and 2

On September 29, 2017, OFAC modified Directives 1 and 2 of Executive Order 13662 to reduce the permissible maturity for new debt issued by Russian financial and energy entities designated under these directives, as well as...more

Trump Administration Significantly Expands Sanctions Against North Korea

On September 21, 2017, the White House announced additional sanctions against North Korea, following a new round of sanctions imposed by the United Nations on September 11 and an escalation of U.S. sanctions previously...more

President Trump and OFAC Announce Targeted Economic Sanctions on Venezuela

On August 25, 2017, President Trump issued an Executive Order (EO) imposing economic sanctions related to Venezuela. The new measures prohibit U.S. persons from engaging in certain debt-, equity-, and securities-related...more

Trump Administration Makes First Iran Sanctions Designations

Key Points - - The U.S. Department of the Treasury’s Office of Foreign Assets Control has added 25 new entities and individuals to its Specially Designated Nationals List, including some located in China, Lebanon,...more

United States Imposes Cybersecurity Sanctions on Russia

Key Points - - This action marks the first time sanctions have been imposed under the Cybersecurity Sanctions Program established on April 1, 2015, with the designation of nine entities and individuals. -...more

OFAC Issues Venezuela Sanctions Regulations

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published, in abbreviated form, Venezuela Sanctions Regulations (VSR) in 31 C.F.R. Part 591. The VSR implement the Venezuela...more

Obama Signs Executive Order Establishing Cybersecurity Sanctions Regime

On April 1, 2015, President Obama signed an executive order establishing a new sanctions program targeting individuals and entities responsible for, or complicit in, cyber-enabled activities that threaten the national...more

U.S. Implements Targeted Sanctions on Venezuela

On March 9, 2015, following failed diplomatic efforts to bring Venezuela in line with its human rights commitments under international law, President Obama issued an Executive Order (E.O.) declaring Venezuela a national...more

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