As discussed in our May 7, 2024 alert, on April 24, 2024, President Biden signed into law a foreign military support package (i.e., H.R. 815), which included a provision doubling the statute of limitations (“SOL”) from five...more
9/24/2024
/ Civil Monetary Penalty ,
Cuban Assets Control Regulations (CACR) ,
Department of Labor (DOL) ,
Economic Sanctions ,
Enforcement ,
Interim Final Rules (IFR) ,
International Emergency Economic Powers Act (IEEPA) ,
Investigations ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Regulatory Requirements ,
Statute of Limitations ,
TWEA
Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities -
SUMMARY -
On April 24, 2024, President Biden signed into law a foreign military...more
5/8/2024
/ Bureau of Industry and Security (BIS) ,
Department of Justice (DOJ) ,
Due Diligence ,
Export Administration Regulations (EAR) ,
Export Control Reform Act (ECRA) ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Sanction Violations ,
Self-Disclosure Requirements ,
Statute of Limitations ,
Trading with the Enemy Act ,
Voluntary Disclosure
Articulates Administration Policy And Creates New Made In America Office To Review Proposed Waivers Of “Made In America Laws” -
On January 25, 2021, President Joseph R. Biden Jr. signed an Executive Order on Ensuring the...more
On February 13, 2020, two Final Rules issued by the Committee on Foreign Investment in the United States’ (“CFIUS”) implementing most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”) became...more
Report from the 2019 Mayors’ Annual Energy Summit in Carlsbad, NM -
We attended the Mayors’ Annual Energy Summit again this year, on September 12, at the Walter Gerrells Civic Center Annex in Carlsbad, NM. The Mayors’...more
10/14/2019
/ Arbitration ,
CFIUS ,
Climate Change ,
DIFC ,
Energy Policy ,
Energy Sector ,
Energy Summit ,
Foreign Investment ,
Human Rights ,
Oil & Gas ,
Project Finance
On September 17, 2019, the Committee on Foreign Investment in the United States (“CFIUS”) published two Proposed Rules to implement most of the Foreign Investment Risk Review Modernization Act of 2018 (“FIRRMA”). CFIUS is an...more
9/19/2019
/ CFIUS ,
Critical Infrastructure Sectors ,
Cybersecurity ,
FIRRMA ,
Foreign Investment ,
Infrastructure ,
Personal Data ,
Personally Identifiable Information ,
Proposed Rules ,
Real Estate Transactions ,
Technology Sector
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
Lessons for Sellers in Contracting with Emerging Market Buyers: The “Three R’s” to Structuring Payment Security Provisions -
The recent rebound in the international energy industry is being driven, at least in part, by a...more
6/18/2018
/ BSEE ,
Cloud Computing ,
Energy Policy ,
Energy Sector ,
Exports ,
FERC ,
Joint Comprehensive Plan of Action (JCPOA) ,
Migratory Bird Treaty Act (MBTA) ,
Natural Gas ,
Oil & Gas ,
Pipelines ,
Proposed Rules ,
Trump Administration ,
Well Drilling
On May 8, 2018, President Donald Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) negotiated between the “P5+1” countries (United States, United Kingdom, France,...more
As part of its ongoing efforts under the new Miscellaneous Tariff Bill (“MTB”) process, the U.S. International Trade Commission (“ITC”) announced last Friday that it would accept additional public comments on certain MTB...more
On February 3, 2017, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury added twenty-five individuals and entities to its Specially Designated Nationals (“SDN”) List. According to the White...more
On January 13, 2017, President Obama signed Executive Order 13761 (“E.O. 13761”), “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions.” Effective July...more
The U.S. International Trade Commission (“ITC”) is now accepting public comments on Miscellaneous Tariff Bill (“MTB”) petitions for duty suspensions and reductions that timely were filed with the agency by December 12, 2016,...more
More than 1,000 petitions seeking temporary duty suspensions and reductions pursuant to the American Manufacturing Competitiveness Act of 2016 (the Act) have been filed with the U.S. International Trade Commission (ITC). As...more
The U.S. International Trade Commission (“ITC”) has begun accepting petitions seeking temporary duty suspensions and reductions pursuant to the American Manufacturing Competitiveness Act of 2016 (“the Act”). The Act...more
What the Next President Should Do About U.S. Manufacturing -
Top industry executives, political leaders, small business and trade union leaders, researchers and policymakers are offering a blueprint for maintaining the...more
10/14/2016
/ Administrative Law Judge (ALJ) ,
Anti-Dumping Duty ,
Customs and Border Protection ,
Cybersecurity ,
Drones ,
Energy Reform ,
Enforcement ,
Geothermal Energy ,
Global Economy ,
Imports ,
International Trade Commission (ITC) ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
Political Campaigns ,
Public Forum ,
Public Land ,
Public Policy ,
Russia ,
Sanctions ,
Steel Industry ,
Tariffs ,
Unmanned Aircraft Systems ,
Water
On October 5, 2016, the U.S. Department of State (State Department) announced the final version of a Joint Declaration for the Export and Subsequent Use of Armed or Strike-Enabled Unmanned Aerial Vehicles (UAVs) (the Joint...more
Following the Federal Aviation Administration’s rollout of final regulations governing the use of certain commercial drones in the National Airspace, Defense News reports that the United States has taken steps to facilitate...more