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U.S. Treasury implements Final FIRRMA Regulations

INTRODUCTION - This week, new regulations promulgated by the U.S. Department of the Treasury (the Treasury) went into effect to finalize and comprehensively implement the Foreign Investment Risk Review Modernization Act of...more

Liability for breaches of sanctions: financiers, lessors and charterers beware, OFAC settles claims against Apollo and Eagle Bulk

Two recent settlements in the United States have highlighted the risks for parties involved in aviation and shipping of incurring liabilities for a breach of sanctions. ...more

Updated Equator Principles Finalized

Updated Equator Principles with stronger standards and a broader scope were finalized in November 2019 and are set to come into effect in July 2020. ...more

Consultation on update of the Commission’s “Blue Guide” on EU product rules

The European Commission has invited stakeholders to comment on issues that should be included in the next update of the Blue Guide on the implementation of EU product rules (the Blue Guide). The invitation can be found here....more

1/15/2020  /  EU , EU Directive , European Commission

CFIUS Creates New Pilot Program for Mandatory Declarations

On Aug. 13, 2018, Congress expanded the authority of the U.S. Treasury Department’s Committee on Foreign Investment in the United States (CFIUS) to review certain transactions resulting in non-US control of US assets,...more

U.S. EPA Proposes to Relax Power Plant Carbon Emissions Restrictions, Fulfilling Trump Campaign Promise

On August 21, 2018, the U.S. Environmental Protection Agency (EPA) published its proposed Affordable Clean Energy (ACE) rule, fulfilling a Trump campaign promise to eliminate strict coal plant emission limits that President...more

Dealmakers Beware: Trump Expands CFIUS’ Reach

On August 13, 2018, President Donald Trump expanded the powers of the Committee on Foreign Investment in the United States (CFIUS) to review foreign investments in the United States by signing into law the Foreign Investment...more

Buyer Beware: CFIUS's Expanding Reach

Introduction - Although the Committee on Foreign Investment in the United States (CFIUS) has been evaluating foreign investment for implications to U.S. national security interests since 1975, its authority has expanded...more

China RoHS 2 Catalogue Finalized

BACKGROUND - In 2006, China passed a law regulating the use of six hazardous substances found in certain electronic equipment. This law was modelled on a similar EU Directive, and was informally referred to as “China RoHS1”....more

New Executive Order Seeks to Jump Start the Effort to Rebuild America’s Infrastructure

“Crumbling infrastructure will be replaced with new roads, bridges, tunnels, airports, and railways gleaming across our very, very beautiful land.” President Donald J. Trump - The new Executive Order on infrastructure...more

Trump Administration Re-Certifies Iranian Compliance with the Joint Comprehensive Plan of Action but Applies New Sanctions to...

The Trump administration recently re-certified that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA, otherwise known as the “Iran Deal”), thereby extending the sanctions relief afforded to Iran...more

New Iran Designations: OFAC Adds 25 Persons to the SDN List in Response to Iran’s Ballistic Missile Test

On February 3, 2017, the U.S. Office of Foreign Assets Control (OFAC) added 25 persons to its List of Specially Designated Nationals and Blocked Persons (the SDN List, and every person thereon, an SDN) as a result of their...more

OFAC Authorizes Certain Dealings with Russian Security Agency

In its first public statement since the inauguration, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) announced on February 2, 2017, that it had authorized limited dealings with the Federal Security...more

Leaving on a Reconciliatory Note: President Obama Ends His Term with a Substantial Easing of the Sudanese Sanctions Regime

The U.S. Department of the Treasury (Treasury) recently announced a significant relaxation of the U.S. sanctions with respect to Sudan that are currently administered by the Office of Foreign Assets Control (OFAC). The...more

New U.S. Sanctions Concerning Russia: President Obama Logs Out of 2016 with an Amendment to the U.S. Cyber-related Sanctions...

On December 29, 2016, OFAC (the U.S. Department of the Treasury, Office of Foreign Assets Control) imposed sanctions on five Russian entities and four Russian individuals in connection with their alleged efforts to interfere...more

The U.S. Department of the Treasury, Office of Foreign Assets Control Ends Its ‘Burma Sanctions Program’

On 7 October 2016, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) ended all economic and financial sanctions with respect to Myanmar (referred to by OFAC as Burma). The move had been...more

OFAC Expands List of Persons Subject to Sanctions Under Ukraine-/Russia-Related Sanctions Authorities

On September 1, 2016, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury (Treasury) designated 37 new individuals and entities as Specially Designated Nationals and Blocked Persons (SDNs)...more

D.C. Court of Appeals Denies Request for Rehearing on Conflict Minerals Rules

On November 9, 2015, the U.S. Court of Appeals for the District of Columbia Circuit denied petitions filed by the Securities and Exchange Commission (SEC) and Amnesty International requesting a full panel rehearing of its...more

Vienna Deal Brings Iran In From The Cold

After months of wrangling, a deal has finally been reached allowing Iran to develop a peaceful domestic nuclear programme with the lifting of economic and financial sanctions.This is on the strict proviso that Iran does not...more

OFAC Revises the “50% Rule” with Regards to Aggregate Ownership

On August 13, 2014, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued revised guidance relating to the status of entities owned by individuals or entities whose property and...more

New EU sanctions in relation to Ukraine

On July 18, 2014, the European Council adopted Regulation (EU) No 783/20141 which expanded the scope of individuals, entities and bodies who could be added to the list of sanctions targets. Those materially or financially...more

Extension Of The Sanctions Relief Provided For In The Joint Plan Of Action Between The P5+1 And The Islamic Republic Of Iran

On July 18, 2014, the P5+1 (the United States, the United Kingdom, Germany, France, Russia, and China) agreed with Iran to extend their commitments under the Joint Plan of Action (JPOA). The JPOA, originally agreed upon in...more

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