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U.S. moves towards (but stops short of) complete embargo on Venezuela

On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more

Re-imposing sanctions on Iran, Trump discards nuclear deal

On 5 November 2018 the United States re-imposed the remaining nuclear-related secondary sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) against Iran that previously had...more

Iran sanctions: Snapback becomes reality

The United States has begun re-imposing nuclear-related sanctions with respect to Iran in connection with the expiration of the 90-day wind-down period announced alongside the United States' 8 May 2018 withdrawal from the...more

BIS expands Entity List with addition of 44 Chinese parties

Export compliance continues to be complicated for companies involved in business with China. On 1 August 2018, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) expanded the Entity List, restricting...more

U.S. stays the course on re-imposing Iran sanctions

In furtherance of President Trump’s 8 May 2018 announcement that the United States would withdraw from the Iran nuclear deal—the Joint Comprehensive Plan of Action (JCPOA)—on 27 June 2018, the U.S. Department of Treasury’s...more

Cuba update: Trump tightens travel authorizations and targets new restricted parties

On 9 November 2017, the Trump Administration implemented new regulations to support its change to U.S. policy on Cuba. The U.S. Government has created a new Cuba Restricted List administered by the State Department. Through...more

U.S. releases public guidance on entities tied to Russian Defense and Intelligence sectors

On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more

De-Certification and the Iran Nuclear Deal: The Beginning of the End, or Much Ado about Nothing?

Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more

New executive order targets Venezuela’s access to U.S. financial markets

Effective August 25, 2017, President Trump issued a new Executive Order, (the Order), which targets the Government of Venezuela’s (GOV) and Petroleos de Venezuela, S.A.’s (PdVSA) ability to access capital from the United...more

After Washington Drama, New Russia (and Iran and N. Korea) Sanctions Set to Become Law

On Tuesday, July 25, the U.S. House of Representatives passed H.R. 3364, the Countering America’s Adversaries Through Sanctions Act by a vote of 419-3. There is some uncertainty, but the legislation is expected to be...more

Seeking to Restrict Chinese Investment in the U.S., Congress Considering CFIUS Reforms

Lawmakers in both the U.S. House of Representatives and Senate are examining ways to restrict Chinese investment in the United States by reforming national security reviews conducted by the Committee on Foreign Investment in...more

Trump Administration Takes Moderate Steps Against Iran. What Comes Next?

On Friday, February 3, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced it was designating 25 entities and individuals as Specially Designated Nationals (SDNs) for their involvement in...more

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