During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
In a sweeping, coordinated effort across federal agencies, the US government has taken a giant leap forward to prevent access to data that could be exploited to the detriment of national security. On February 28, 2024,...more
On February 28, 2024, the Biden administration announced new cybersecurity-related measures, including an executive order (EO) and advance notice of proposed rulemaking (ANPRM), intended to address the bulk flow of Americans’...more
Florida enacted Senate Bill (SB) 264 (Chapter 2023-33, Laws of Florida) in May 2023 to limit select persons from "foreign countries of concern" from owning, having a controlling interest in or acquiring an interest in certain...more
The Florida Department of Commerce (Department) on Sept. 20, 2023, published proposed rules interpreting Florida's law limiting "foreign principals" from "foreign countries of concern" – China, Russia, Iran, North Korea,...more
Last month, Gov. Ron DeSantis (R) of Florida signed a new law that would prohibit people who are not U.S. citizens or permanent residents and whose "domicile" is in China from purchasing certain real property in the state....more
On May 8, 2023, Gov. Ron DeSantis signed into law Senate Bill 264, creating Florida Statutes sections 692.201 through 692.205, which prohibits the direct or indirect ownership of various categories of real estate by...more
Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...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
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...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
The Information and Communications Technology and Services (ICTS) Rule, if implemented by the Biden Administration, would significantly impact companies that have an international nexus in a number of different sectors,...more
This quarter, the U.S. announced new sanctions and trade restrictions on China in response to its recent encroachments on Hong Kong and its reported mistreatment of ethnic minorities. OFAC continued to target shipping...more
Recognizing that COVID-19 is further straining humanitarian needs in sanctioned countries and complicating compliance with economic sanctions, and perhaps also in response to reports that US sanctions are hindering COVID-19...more
Seyfarth Synopsis: Within the last few days, the Trump Administration has expanded an existing travel ban and initiated a new one related to the Coronavirus; similarly other countries have added entry restrictions to try to...more
The new Iran sanctions imposed by the Trump Administration are not the only recent sanctions actions of note. Congress has also shown its willingness to use sanctions as a foreign policy tool, with certain sanctions...more
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
In this quarter, OFAC lifted sanctions on Rusal and other companies following divestment by Oleg Deripaska. Meanwhile, as Venezuela descends into economic and political crisis, the US targeted PdVSA and others to hasten...more
Closing out 2018, OFAC announced its plan to lift sanctions against United Co. Rusal and others, despite bi-partisan opposition from Congress. Simultaneously, OFAC continued to target Russia’s defense and intelligence sectors...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
Happy new year everyone. The government is shut down, but there has already been a flurry of activity in 2019 on the economic sanctions and embargoes front. Here is a summary of where we stand on various sanctions regimes....more
Russia remained at the forefront this quarter, as the Trump Administration imposed new measures and markets reacted to the threat of additional, “crushing” sanctions from Congress on Russian sovereign debt. Meanwhile, EU...more