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…
The Biden Administration has signaled an expanded commitment to longstanding U.S. anti-corruption policies, and recent enforcement actions and policy announcements provide insights into what foreign officials, companies and investors can expect. Early signs indicate an intent both to bolster core anti-corruption enforcement through the Foreign Corrupt Practices Act (FCPA) and…
TAKEAWAYS The prior Administration’s November 2020 Executive Order (E.O.) 13959 prohibited U.S. persons from engaging in the purchase or sale of any publicly traded securities of designated Communist Chinese Military Companies (CCMCs). Given that several companies designated as CCMCs had successfully challenged their designation in the U.S. courts, the new…
As part of its continuing efforts to protect US communications networks from communications equipment and services that pose a national security risk, the Federal Communications Commission (FCC) on June 17, 2021, released a Notice of Proposed Rulemaking and Notice of Inquiry (NPRM/NOI) seeking comments on its proposal to prohibit the…
On April 26, 2021, the UK announced a new global anti-corruption sanctions regime and has imposed sanctions on 22 people whom the UK Government has reasonable grounds to suspect have been involved in serious corruption. Under the new Global Anti-Corruption Sanctions Regulations 2021 (SI 2021/488), those designated will be subject…
U.S., UK and EU authorities continue to expand sanctions targeting the Tatmadaw, Myanmar’s armed forces, following the February 1, 2021 military coup in Myanmar (also known as Burma). Over the past month, the United States and its European allies have imposed blocking and other sanctions on (a) the two major…
On April 15, 2021, the U.S. Government announced broad new sanctions authorities that can be used to target Russia and implemented limitations on dealings in Russian sovereign debt. These measures were imposed pursuant to a newly issued Executive Order in response to Russia’s alleged election inference, the SolarWinds cyberattack, and…
On 22 March 2021, the EU added 11 Burmese officials responsible for last month’s military coup in Myanmar to its sanctions list. The designations are made in response to “the illegitimate over-throwing of the democratically-elected government and the brutal repression by the junta against peaceful protesters” under Council Implementing Regulation…
U.S. officials have continued to use a range of policy tools to apply pressure on the military leadership of Myanmar (also known as Burma) in response to the military coup in the country and escalating violence against peaceful protestors. These moves have continued to follow a step-by-step approach, with important…
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…