The Trump administration continues to ramp up sanctions on Venezuela and Yemen's Houthis, while sending mixed signals about its intentions with respect to Russia. We provide brief updates on these three areas, following up...more
3/11/2025
/ Economic Sanctions ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Popular ,
Regulatory Reform ,
Russia ,
Terrorist Organizations ,
Trump Administration ,
U.S. Treasury ,
US Trade Policies ,
Venezuela ,
Yemen
With an array of unprecedented executive orders and other policies, the Trump administration’s “America First” trade strategy is beginning to take shape. As we monitor these developments, it is becoming increasingly clear...more
3/4/2025
/ CFIUS ,
China ,
Economic Sanctions ,
Executive Orders ,
Export Controls ,
Forced Labor ,
Foreign Investment ,
ITAR ,
National Security ,
Popular ,
Trump Administration ,
US Trade Policies ,
Uyghur Forced Labor Prevention Act (UFLPA)
On February 20, 2025, the U.S. Departments of State and the Treasury designated eight Latin American drug trafficking cartels as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs), in...more
2/25/2025
/ Anti-Terrorism Financing ,
Cartels ,
Cooperative Compliance Regime ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Foreign Policy ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
SDN List ,
Terrorist Financing Regulations ,
Trafficking ,
Trump Administration
A groundbreaking new regulatory regime, imposing rules unlike any in existing U.S. law, may surprise many companies due to its sudden adoption and complexity. This article tries to simplify the changing regulatory landscape,...more
2/19/2025
/ China ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Data Security ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Final Rules ,
Foreign Adversaries ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
International Data Transfers ,
National Security ,
Protecting Americans Data from Foreign Adversaries Act (PADFA) ,
Regulatory Reform ,
Regulatory Requirements
On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more
2/18/2025
/ Anti-Corruption ,
Cooperative Compliance Regime ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Regulatory Agenda ,
Regulatory Freeze ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblowers
We find ourselves in the midst of a raucous debate among sanctions practitioners about the impact of the Fifth Circuit’s recent decision upholding a challenge against the sanctions the Office of Foreign Assets Control (OFAC)...more
2/5/2025
/ Blockchain ,
Cryptocurrency ,
Decentralized Autonomous Organization (DAO) ,
Digital Assets ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Statutory Interpretation
Days before President Biden leaves the White House, the U.S. government has delivered a major blow against Russia. On January 10, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced...more
1/17/2025
/ Biden Administration ,
Economic Sanctions ,
Energy Sector ,
Export Controls ,
Foreign Policy ,
Infrastructure ,
Liquid Natural Gas ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
U.S. Treasury
In this episode of the Crypto Exchange, Ethan Ostroff is joined by colleagues Pete Jeydel and Matt Orso to discuss a recent landmark decision from the Fifth Circuit regarding Tornado Cash. The court ruled that the Office of...more
The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) on January 3, 2025, seeking public input to inform the potential development of a rule to secure...more
1/10/2025
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Bureau of Industry and Security (BIS) ,
China ,
Cybersecurity ,
Data Security ,
Drones ,
National Security ,
Proposed Rules ,
Regulatory Agenda ,
Risk Assessment ,
Supply Chain ,
Technology Sector ,
U.S. Commerce Department ,
Unmanned Aircraft Systems