News & Analysis as of

Office of Foreign Assets Control (OFAC) International Emergency Economic Powers Act (IEEPA) Executive Orders

Holland & Knight LLP

Commerce Department: Final Determination of Russia-Backed Cybersecurity, Antivirus Software

Holland & Knight LLP on

The U.S. Department of Commerce's Office of Information and Communications Technology and Services (OICTS) within the Bureau of Industry and Security (BIS) issued a Final Determination on June 20, 2024, pursuant to Executive...more

Ankura

Operational Implications of the New Bulk Sensitive Data Executive Order

Ankura on

On February 28, 2024, President Biden signed Executive Order 14117 (the EO), on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” The United...more

Bracewell LLP

Amid a Minefield of Sanctions and Export Controls, Here's How to Provide Aid to Ukraine

Bracewell LLP on

Over the past week, the Biden Administration has announced unprecedented sanctions and export controls against Russia in response to its unprovoked invasion of Ukraine. As the State Department pledges an additional $350...more

Wiley Rein LLP

OFAC Issues Chinese Military-Industrial Complex Sanctions Regulations

Wiley Rein LLP on

On February 16, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “abbreviated” regulations to implement President Biden’s 2021 Executive Order (EO) barring certain investments in...more

Foley & Lardner LLP

White House Issues Open Letter to Private Businesses Regarding the Threat of Ransomware

Foley & Lardner LLP on

On June 2, 2021, Anne Neuberger, Deputy Assistant to the President and Deputy National Security Advisor for Cyber and Emerging Technology, published a rare open letter to the corporate executives and business leaders of...more

Morgan Lewis

OFAC Publishes Hong Kong Sanctions Regulations: Implications for Business With Hong Kong Entities

Morgan Lewis on

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published final rules on January 15, 2021, implementing the sanctions put in place by Executive Order 13936 (EO 13936) and the Hong Kong Autonomy Act...more

Dorsey & Whitney LLP

Trump Administration Bars U.S. Investments in Certain Chinese Companies Linked to Chinese Military

Dorsey & Whitney LLP on

On November 12, 2020, President Trump issued Executive Order 139591 (“the Order”) that will shortly bar any U.S. person from “any transaction in publicly traded securities, or any securities that are derivative of, or are...more

Morgan Lewis

Implications of the New Executive Order Prohibiting Transactions in Publicly Traded Securities of Chinese Military Companies

Morgan Lewis on

The new Executive Order (EO or the Order) bans transactions by US persons in publicly traded securities of companies identified as “Chinese military companies,” and includes a ban on trading in derivatives of those securities...more

Morrison & Foerster LLP

Trump Administration Gives Teeth To Pentagon List And Restricts U.S. Investment In Publicly Traded Securities Of Chinese Military...

Morrison & Foerster LLP on

Over the past summer, prompted by a bipartisan Congressional letter identifying a two‑decade‑old statute as an unused tool in confronting China’s strategy of “Military-Civilian Fusion,” the U.S. Department of Defense (“DOD”)...more

Wilson Sonsini Goodrich & Rosati

As the App World Turns: Halt on Implementation of Commerce Prohibitions Regarding TikTok and WeChat

This past weekend saw a halt to the anticipated September 20 implementation of broad prohibitions published on September 18 by the U.S. Department of Commerce (Commerce) regarding TikTok and WeChat mobile applications. No...more

Wilson Sonsini Goodrich & Rosati

U.S. Department of Commerce Publishes Transactions with ByteDance and Tencent That Are Prohibited Due to National Security...

On September 18, 2020, the U.S. Department of Commerce issued two orders identifying the specific transactions related to the WeChat and TikTok mobile applications ("Orders") that are prohibited pursuant to Executive Orders...more

Alston & Bird

Uncertainty Surrounds Forthcoming Commerce Department Action on TikTok & WeChat “Bans”

Alston & Bird on

As the countdown continues to September 20, our International Trade & Regulatory Group examines the ambiguities underlying the unprecedented Executive Orders purporting to ban the use of TikTok and WeChat, questions that may...more

ArentFox Schiff

US Administration Takes on Chinese Social Media

ArentFox Schiff on

President Trump signed an Executive Order (EO) (TikTok EO) August 6, 2020, banning “transactions” yet to be identified by the US Department of Commerce (Commerce) related to TikTok and its parent ByteDance Ltd. Specifically,...more

Bass, Berry & Sims PLC

U.S. District Court Deals Rare Defeat to OFAC in U.S. Sanctions Matter

Bass, Berry & Sims PLC on

• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more

ArentFox Schiff

US Administration Tests the Water on New Unheard-of Government Review of International Technology Transactions

ArentFox Schiff on

Under this new evaluation process, Commerce can prohibit companies from engaging in a wide variety of transactions and order them to cease using the information technology or telecommunication system in question even if it is...more

Holland & Hart LLP

OFAC Redefines the Term “Significant Transnational Criminal Organization,” Broadening Its Reach

Holland & Hart LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has implemented the President’s prior revision of the definition of “significant transnational criminal organization” (significant TCO) by...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2019

ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more

Sheppard Mullin Richter & Hampton LLP

New Executive Order To Further Restrict Business with Huawei and Other Foreign Adversaries Engaged in Cyber Espionage

On May 15, 2019, President Trump issued an Executive Order (“EO”) targeting activities of certain foreign telecommunications companies based in hostile countries. Entitled “Securing the Information and Communications...more

Faegre Drinker Biddle & Reath LLP

President Trump Prohibits Most Trade and Transactions with Huawei of China and Sets the Stage for Similar Actions against other...

On May 15, 2019, President Trump issued an Executive Order (EO), “Securing the Information and Communications Technology and Services Supply Chain.” The EO directs the U.S. Department of Commerce to lead an interagency effort...more

Dechert LLP

U.S. Escalates Sanctions Against PdVSA, Venezuela

Dechert LLP on

On January 28, 2019, the United States imposed blocking sanctions on Petróleos de Venezuela SA (“PdVSA”), the Venezuelan state-owned oil company. The measures follow President Trump’s recent decision to recognize Juan Guaidó,...more

Hogan Lovells

Win some, lose some: U.S. Russia sanctions developments

Hogan Lovells on

The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Arabic

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Spanish

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - SEC Proposes Amendments to Whistleblower Award Program - On June 28, 2018, the Securities and Exchange Commission (SEC) proposed amendments to its whistleblower award process for the first...more

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