On December 8, 2021 the EU Commission published its proposal for a new “Anti-Coercion Instrument.” The regulation is being proposed in response to targeted deliberate economic pressures applied to the EU and its Member States in recent years and seeks to deter countries from restricting or threatening to restrict trade…
On July 30, 2021, the Biden Administration published a Proposed Amendment to the Federal Acquisition Regulation (FAR) (Proposed Rule) that, among other things, would impose significantly increased U.S. content requirements for U.S. Government procurements when the Buy American Act of 1933 (BAA) applies. These increases follow a trend of tightening…
On March 2, 2021, the U.S. Department of the Treasury’s Office of Asset Controls (OFAC) imposed sanctions on two key militant leaders of the Iranian-backed Ansarallah, also known as the Houthis. OFAC sanctions target Mansur Al-Sa’adi, Houthi naval forces chief of staff, and Ahmad ‘Ali Ahsan al-Hamzi, commander of Houthi…
On a recent episode of The fDi Podcast, titled “Hunting for String in the Labyrinth. How Can Investors Safely Navigate Current Sanctions Regime?”, Pillsbury Public Policy partner Matt Oresman joined host Jacopo Dettoni to discuss the current U.S. sanctions landscape and identify some of the important factors businesses must consider…
On November 27, 2019, the US Commerce Department published a proposed rule implementing regulations following President Trump’s May 15, 2019 Executive Order 13783 (E.O.) on Securing the Information and Communications Technology and Services (ICTS) Supply Chain. The proposed rule adopts an open-ended, case-by-case review framework by which the Commerce Department…
Further to our prior blog post, on May 13, 2019, at the direction of President Trump, the Office of U.S. Trade Representative (USTR) published a proposed tariff list covering approximately $300 billion worth of Chinese imports to be subject to higher duties pursuant to the determinations previously made under Section…
On February 4, 2019, U.S. Customs and Border Protection (CBP) issued a withhold release order (WRO) against tuna and tuna products from the Tunango No. 61, a Taiwanese vessel, based on information obtained by CBP that indicated that tuna is harvested with the use of forced labor. The order will…
On November 5, 2018, OFAC announced a large number of Iran-related sanctions designations and issued guidance on the end of the 180-day wind down period. The announced list of Specially Designated Nationals (SDNs) both reinstated prior sanctions that had been suspended during implementation of the Joint Comprehensive Plan of Action…
Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing (1) FAQs on April 3, 2018 and (2) a ruling on May 16, 2018 providing…
Yesterday, President Trump issued a memorandum (“Memorandum”) directing his Administration to take several actions related to the investigation by the Office of U.S. Trade Representative (“USTR”) into China’s acts, policies, and practices (“APPs”) related to technology transfer, intellectual property, and innovation under Section 301 of the Trade Act of 1974…