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United States, European Union and United Kingdom Intensify Sanctions on Burma

On March 25, 2021, the United States imposed sanctions on Myanma Economic Holdings Public Company Limited ("MEHL") and Myanmar Economic Corporation Limited ("MEC"), Burma's two largest military conglomerates. On the same day,...more

US and EU impose coordinated Navalny sanctions

On 2 March 2021, the United States and European Union ("EU") imposed coordinated sanctions in response to the poisoning and imprisonment of Russian opposition politician Aleksey Navalny (and the related US determination that...more

US Commerce Department issues “Military End User” List

On December 23, 2020, the US Department of Commerce's Bureau of Industry and Security ("BIS") issued a final rule creating a "Military End User List" ("MEU List") under the Export Administration Regulations ("EAR"). The final...more

FCC Adopts New Rules and Procedures for Team Telecom Committee

On September 30, 2020, the Federal Communications Commission (FCC) voted to adopt a Report and Order that provides for new rules and procedures to formalize the review process of the Committee for the Assessment of Foreign...more

New CFIUS Critical Technology Mandatory Filing Requirements Take Effect October 15th

On September 15, 2020, the US Treasury Department published a final rule modifying the mandatory Committee on Foreign Investment in the United States (CFIUS) filing requirements for certain foreign investments in US...more

BIS Issues Rules on the Scope of Entity List Restrictions and Significantly Limits Activities Involving Huawei

On August 17, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) issued two final rules that expand the scope of licensing requirements for transactions involving parties on the Entity List. Both rules...more

CFIUS Annual Report for 2019 Shows Key Trends; TikTok Faces CFIUS Review and, Together with WeChat, Other US Restrictions

In late July, the Committee on Foreign Investment in the United States (CFIUS) released its Annual Report for 2019, providing insight into recent CFIUS trends. This included encouraging results on CFIUS outcomes for...more

CFIUS Update: Proposed Changes to Critical Technology Mandatory Filing Requirements; 2018-2019 Statistics Show Key Trends; CFIUS...

There have been several recent developments related to the Committee on Foreign Investment in the United States (CFIUS). Most notably, CFIUS has released a proposed rule that would change the mandatory filing criteria for...more

US Commerce Department Increases Scrutiny and Restrictions on Exports with Particular Focus on China, Russia and Venezuela

On April 28, 2020, the US Commerce Department's Bureau of Industry and Security (BIS) published two new final rules amending the Export Administration Regulations (EAR). One of the final rules removes license exception Civil...more

CFIUS Update: Filing Fees Take Effect May 1

On April 29, 2020, the US Treasury Department published an interim rule establishing fees for parties filing a formal written notice of a transaction for review by the Committee on Foreign Investment in the United States...more

‘Team Telecom’ Formalized into New Committee; Increased Scrutiny of Chinese Involvement in US Telecommunications Services...

On April 4, 2020, President Trump issued an Executive Order (EO) establishing the ‘Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector’ (the Committee). The Committee...more

CFIUS Update: Treasury Proposes CFIUS Filing Fees & President Trump Blocks Another Transaction

The regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which significantly expanded the jurisdiction and authorities of the Committee on Foreign Investment in the United States...more

New Sanctions Target Iran’s Metals, Construction, Mining, Manufacturing, and Textiles Industries

On January 10, 2020, the President signed a new Executive Order (EO), "Imposing Sanctions With Respect to Additional Sectors of Iran," targeting Iran's construction, mining, manufacturing, and textiles industries. On the same...more

Department of Commerce Invites Comments on Proposed Rule Targeting Information and Communications Technology Transactions

On November 27, 2019, the US Department of Commerce (Commerce) issued a notice of proposed rulemaking on the implementation of Executive Order 13873 (the EO), "Securing the Information and Communications Technology and...more

CFIUS: Proposed FIRRMA Regulations Define CFIUS's Expanded Jurisdiction and Mandatory Filing Requirements

On September 17, the US Department of the Treasury issued comprehensive proposed regulations to implement the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). This alert describes key aspects of the proposed...more

US Imposes Additional Sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act

On August 2, 2019, the United States announced the imposition of additional sanctions on the Russian Federation under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act)....more

US Designates Huawei to Entity List, Issues Temporary General License

The US Commerce Department’s Bureau of Industry and Security (BIS) added Huawei Technologies Co., Ltd. (Huawei) and 68 non-US Huawei affiliates to the BIS Entity List, effective May 16, 2019, at 4:15 p.m. Eastern Daylight...more

Iran Threatens Partial JCPOA Suspension; US Imposes Sanctions on Certain Iranian Metals Sectors

On May 8, 2019, following Iran's announcement that it intends to suspend certain nuclear proliferation-related commitments under the Joint Comprehensive Plan of Action (JCPOA), the United States issued a new Executive order...more

UK, France, Germany create INSTEX SPV to support trade with Iran

On 31 January 2019, France, Germany and the United Kingdom (the "E3") announced the registration in France of INSTEX SAS ("Instrument for Supporting Trade Exchanges"), which is a special purpose vehicle aimed at facilitating...more

United States Expands Venezuela Sanctions, Targets PdVSA

On January 28, 2019, the Department of the Treasury's Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) on the List of Specially Designated Nationals and Blocked Persons (SDN List). PdVSA...more

OFAC Delists En+ Group, Rusal, and EuroSibEnergo

On January 27, 2019, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) lifted sanctions imposed on En+ Group plc (En+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE), removing these entities from...more

EU sanctions Syrian and Russian parties involved in the use and proliferation of chemical weapons

On 21 January 2019, the EU adopted the first sanctions measures under its new sanctions framework targeting parties involved in the use and proliferation of chemical weapons introduced in October 2018...more

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