The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
EMBARGOED! Episode 43: Russia and Iran and China, Oh My!
Washington Post Journalist Jason Rezaian on His Iranian Imprisonment
Nota Bene Episode 64: U.S. Check In: Prescription Drugs, USMCA, Privacy, Impeachment and Iran with Elizabeth Frazee and Jonathan Meyer
Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia. ...more
In October, the U.S. Commerce Department unveiled new rules to tighten further a sweeping set of export controls first introduced a year previously, reducing the types of semiconductor manufacturing equipment and advanced...more
On February 24, the two-year anniversary of Russia’s invasion of Ukraine, the Biden administration issued hundreds of new Russia-related export controls and sanctions. The Office of Foreign Assets Control (OFAC) and the...more
In 2023, the biggest question on clients’ minds was the ramping up of U.S. export controls targeting semiconductors and advanced computing. In October, the U.S. Commerce Department unveiled new rules to tighten further a...more
On January 23, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) released a new rule to expand and strengthen its existing export control restrictions under the Export Administration Regulations...more
Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more
October saw two major enforcement actions involving Russia. First, three individuals were indicted for facilitating the export of controlled U.S.-origin electronics to Russia. Second, the president of a U.S. steel trading...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
On June 16, the U.S. Department of Commerce published a final rule, to be effective July 17, implementing the Protecting Americans’ Sensitive Data From Foreign Adversaries and amending the Securing the Information and...more
May saw several Russia-related enforcement and other actions. The Department of Justice (DOJ) identified and charged three foreign nationals with violating export control laws as they attempted to circumvent Russian...more
In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their...more
The centrality of international trade laws in the development and execution of U.S. foreign policy has never been more evident than in 2022. Companies that have not invested in international trade compliance programs are...more
President Joe Biden signed into law the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 (2023 NDAA or Defense Bill) on Dec. 23, 2022. The Defense Bill, which passed the U.S. House of Representatives on...more
The Bureau of Industry and Security (“BIS”) in U.S. Department of Commerce has added 34 more companies to its Entity List in its continued expansion of U.S. export controls to address human rights in the Xinjiang Uyghur...more
The U.S. Department of Commerce (Commerce) recently announced its "apparent" need for public comment on key aspects of a mechanism that would license or preclear certain information and communications technology and services...more
Back in May 2019, the Trump Administration issued Executive Order 13873, which was meant to police the use of certain information and communications technology and services (ICTS) purchased from "foreign adversaries." Then,...more
A new rule effective March 22, 2021 establishes a process for the US Department of Commerce to review commercial transactions between US and foreign parties for certain information and communications technology and services...more
Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule. In an interim rule published on, January 15, 2020, the Department of...more
n late January 2021, the U.S. Department of Commerce issued an Interim Final Rule (Interim Rule) that would empower the Department to prohibit, mitigate and unwind certain categories of transactions with certain foreign...more
Turning to the business of exports from the United States, the next section is a must-read for any company doing business in the United States or from the United States. Or for that matter, any company competing with affected...more
President Trump issued an Executive Order on September 21, 2020 which, effective immediately, imposes secondary sanctions on the transfer and sale of certain conventional arms shipments and the supply of related services to...more
On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more
Despite our political dialogue and the often-heard charges of fake news and lying, telling the truth still matters in a variety of contexts. For example, Special Counsel Mueller has made various characters in the Russia...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more