The United States has substantially expanded economic sanctions and export controls targeting Russia and Belarus, imposing new restrictions that could have a major impact on companies with business activities in or relating...more
The 21st Century Peace Through Strength Act became law recently as part of H.R. 815, which also provided aid to Ukraine, Israel and Taiwan. The law contains important sanctions measures that: Extend the statute of...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced two enforcement actions this year. Both reference the Financial Crimes Enforcement Network's (FinCEN) whistleblower program,...more
The Committee on Foreign Investment in the United States (CFIUS) has taken another significant step in transforming from a limited jurisdiction interagency committee that primarily reviewed voluntary filings into a body with...more
President Biden issued an executive order on December 22, 2023 targeting evasion of U.S. sanctions on Russia. Executive Order 14,114: Authorizes sanctions on foreign financial institutions (“FFIs”) determined to have...more
The United States has strengthened economic sanctions and export controls targeting Russia, following through on commitments made at a G7 summit this month. The EU and UK also plan to substantially expand measures targeting...more
On April 19, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $300 million civil penalty on Seagate Technology LLC, a U.S. supplier of data-storage products. BIS found that...more
Effective February 5, 2023, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of certain Russia-origin...more
Effective December 5, 2022, a coalition of G7 countries, Australia, and the European Union have generally forbidden service providers to provide certain services relating to the maritime transport of Russia-origin crude oil...more
12/6/2022
/ Australia ,
Economic Sanctions ,
EU ,
Exports ,
G7 ,
General Licenses ,
Maritime Transport ,
Office of Financial Sanctions Implementation (OFSI) ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Oil Prices ,
Russia
On December 2, 2022, the U.S. Department of Commerce (“Commerce”) issued preliminary affirmative determinations of circumvention with respect to crystalline silicon photovoltaic (“CSPV”) cells and modules exported to the...more
12/6/2022
/ Anti-Dumping Duty ,
Cambodia ,
China ,
Countervailing Duties ,
Exporters ,
Imports ,
Malaysia ,
Plastic Solar Cells ,
Solar Panels ,
Tariffs ,
Thailand ,
U.S. Commerce Department ,
US Trade Policies ,
Vietnam ,
Waivers
On October 7, 2022, the U.S. Commerce Department’s Bureau of Industry Security (“BIS”) released new export control regulations (the “New Regulations”) that intensify and complicate U.S. and non-U.S. companies’ international...more
The President has issued the first executive order providing formal direction to the Committee on Foreign Investment in the United States (“CFIUS”) on the risks that it should consider in its examination of foreign investment...more
On August 22, the U.S. Department of Commerce (“Commerce”) postponed its preliminary determinations in the solar panel antidumping and countervailing duty (“AD/CVD”) circumvention proceeding by 90 days. The preliminary...more
The Uyghur Forced Labor Prevention Act (the “Uyghur Act”) came into effect on June 21, 2022. As we described previously, the Uyghur Act establishes a rebuttable presumption that goods mined, produced, or manufactured, in...more
On June 6, 2022, the Biden Administration announced its intention to waive collection of antidumping (“AD”) and countervailing (“CVD”) duties on imports of crystalline silicon photovoltaic (“CSPV”) cells and modules from...more
As part of its continuing response to Russia’s ongoing hostilities in Ukraine, the United States recently imposed additional sanctions and export controls targeting Russia...more
The United States, the European Union and the United Kingdom recently imposed new Russia-related sanctions in response to Russia’s continued hostilities in Ukraine...more
The United States and its allies continue to ramp up pressure on Russia and Belarus in response to Russia’s continued hostilities in Ukraine. In this alert, we describe the latest export, import, and investment bans and...more
Building on the “first tranche” of sanctions announced on February 22, 2022 described in our prior alert, the United States, the EU, the UK, and their allies have imposed (or announced the imposition of) additional...more
3/1/2022
/ Blocking Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
Financial Transactions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SWIFT ,
Ukraine ,
Virtual Currency
In response to the Russian government’s recognition of the Donetsk and Luhansk People’s Republics of Ukraine (the “Covered Regions”) as states and deployment of Russian troops to the Covered Regions, the United States and its...more
On October 21, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published a rule that will restrict some exports, reexports, and other overseas transfers of equipment, software, and technology...more
President Biden issued a new Executive Order 14024 (“E.O. 14024”) on April 15, 2021, expanding sanctions against Russia. E.O. 14024 authorizes, for the first time, U.S. sanctions against Russian technology companies and,...more
4/21/2021
/ Biden Administration ,
Crimea ,
Critical Infrastructure Sectors ,
Defense Sector ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
SolarWinds ,
Sovereign Debt ,
State-Owned Enterprises ,
Technology Contracts
In March 2021, three federal agencies promulgated international trade restraints as part of the Biden Administration’s response to alleged mistreatment of Russian opposition leader Alexey Navalny in 2020. Specifically, the...more
3/31/2021
/ Arms Embargo ,
Biden Administration ,
Bureau of Industry and Security (BIS) ,
CAATSA ,
Economic Sanctions ,
Energy Projects ,
Enforcement Actions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Foreign Policy ,
Foreign Relations ,
Infrastructure ,
ITAR ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
Trade Restrictions ,
US Trade Policies ,
Vessels
In response to a U.S. government consensus that trade with China involves grave national security risks, the Trump Administration promulgated a broad series of China-directed export controls, economic sanctions and import...more
1/28/2021
/ Biden Administration ,
Blocking Statutes ,
China ,
Economic Sanctions ,
Entity List ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Human Rights ,
Infrastructure ,
Military End Use ,
Regulatory Reform ,
US Trade Policies
On January 5, 2021, President Trump issued Executive Order 13971 (the “Executive Order”) that provides for prohibitions on U.S. persons engaging in transactions with persons that develop or control any of the following eight...more
1/11/2021
/ China ,
Data Collection ,
Executive Orders ,
Foreign Policy ,
Mobile Apps ,
National Security ,
Personal Data ,
Popular ,
Prohibited Transactions ,
Social Media ,
Software ,
Trump Administration