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Russia/Ukraine Sanctions Update - Month of April 2025

I. U.S. SANCTIONS  - White House Reportedly Considering Lifting Sanctions on Russian Energy Assets: On April 23, Politico reported that the White House is debating lifting sanctions on Russia’s Nord Stream 2 natural gas...more

Russia/Ukraine Sanctions Update - Month of March 2025

I.  US SANCTIONS - U.S. Agrees to Help Lift International Sanctions on Certain Russian Exports: On March 25, Reuters reported that Washington has agreed “to push to lift some sanctions against Moscow.” This consideration...more

President Trump’s Use of the National Emergency Act and Possible Congressional Next Steps

Recently, President Donald Trump issued three Executive Orders (EOs) to impose tariffs on Mexico, Canada, and the People’s Republic of China (PRC) pursuant to his authorities under the Constitution and the laws of the United...more

Russia/Ukraine Sanctions Update - Month of January 2025

I.  US SANCTIONS - U.S. Department of the Treasury Takes Action Against Russian Efforts to Evade U.S. Sanctions: On January 15, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated...more

President Trump Issues “America First” Trade Policy

At A Glance - The second Trump Administration’s "America First Trade Policy" orders a comprehensive review of US trade and economic policies, focusing on trade deficits, unfair trade practices, and the impact of existing...more

US Commerce Department Finalizes Rule on Connected Vehicles With Supply Chain Links to China and Russia

On January 16, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) addressing national security concerns regarding information and communications technology...more

US Department of Commerce Issues Interim Final Rule Designed to Protect American AI

On January 13, 2025, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an Interim Final Rule (IFR) titled “Framework for Artificial Intelligence Diffusion.” The IFR builds on a long series of...more

Russia/Ukraine Sanctions Update - Month of December

I.  US SANCTIONS - U.S. Department of the Treasury Designates Russian Construction Director and Issues Russia-Related General Licenses: On December 18, the U.S. Department of the Treasury’s Office of Foreign Assets Control...more

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

Russia/Ukraine Sanctions Update - Month of November

I.  US SANCTIONS - US Department of the Treasury Acts to Curtail Russia’s Use of the International Finance System: On November 21, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated...more

Russia/Ukraine Sanctions Update - Month of October

I.  US SANCTIONS - U.S. Department of the Treasury Targets Russian Military-Industrial Producers: On October 30, the U.S. Department of the Treasury announced new sanctions on 275 individuals and entities involved in...more

US Department of the Treasury Issues Final Rule to Regulate Outbound Investments

On October 28, 2024, the US Department of the Treasury (“Treasury”) issued a Final Rule to require the notification or prohibition of certain outbound investments and other transactions by US persons involving persons of...more

Department of Justice Issues Notice of Proposed Rulemaking to Regulate Export of Sensitive Personal Data

On October 21, 2024, the Department of Justice (DOJ) released an unpublished Notice of Proposed Rulemaking (NPRM), Provisions Pertaining to Preventing Access to U.S. Sensitive Personal Data and Government-Related Data by...more

Russia/Ukraine Sanctions Update - Month of September

I.  US SANCTIONS - U.S. Department of the Treasury Acts Against Russian Virtual Currency Exchanges: On September 26, the U.S. Department of the Treasury announced that its Financial Crimes Enforcement Network issued an...more

US Department of Commerce Issues Proposal to Require Reporting Development of Advanced AI Models and Computer Clusters

On September 9, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (BIS) released notice of a proposed rule to create a mandatory reporting requirement for artificial intelligence (AI)...more

BIS Adopts Additional Controls on Quantum, Semiconductor and Additive Manufacturing Technologies in Concert with International...

On September 6, 2024, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) issuing new export controls on quantum computing, semiconductor, and other advanced technology,...more

Russia/Ukraine Sanctions Update - Month of August

US SANCTIONS - US Department of the Treasury Takes Further Action against Russia’s International Supply Chains: On August 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the US...more

BIS Issues First ICTS Ban, Prohibiting Sales and Updates to Kaspersky Products and Services in the US, while OFAC Sanctions Senior...

On June 20, 2024, the Department of Commerce's Bureau of Industry and Security (BIS) issued a Final Determination (“Determination”) prohibiting Kaspersky Lab, Inc.—the US subsidiary of the Russia-based antivirus software and...more

US Congress Extends Statute of Limitations for Sanctions and Export Controls

On April 24, 2024, President Biden signed into law H.R. 815, the National Security Supplemental (the “Act”). While much of the focus centered on the foreign aid package for Israel, Ukraine, and the Indo-Pacific, the bill...more

Russia/Ukraine Sanctions Update - Month of March

I. US SANCTIONS - US Department of the Treasury Sanctions Russian Companies Based on a Determination that They Were Supporting Sanctions Evasion: On March 25, the US Department of the Treasury’s Office of Foreign Assets...more

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

Commerce Considers ICTS-related Rules to Address Connected Vehicle Risks

On March 1, 2024, the US Department of Commerce’s (“Commerce”) Bureau of Industry and Security (“BIS”) published an Advance Notice of Proposed Rulemaking1 (the “Notice”) seeking public comments on potential regulation of the...more

US Agencies’ Tri-Seal Compliance Note Emphasizes Extraterritorial Reach of Sanctions and Export Control Obligations

On March 6, 2024, the US Departments of Commerce (“Commerce”), Treasury (“Treasury”), and Justice (“DOJ”) released their latest Tri-Seal Compliance Note (“Note”), which focuses on the “Obligations of foreign-based persons to...more

Russia/Ukraine Sanctions Update - Month of February

I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more

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