On January 16, 2025, the European Commission issued a recommendation encouraging EU Member States to begin reviewing outbound investments in critical technologies including AI, semiconductors and quantum technologies to assess whether such transactions pose risks to EU economic security (the “Recommendation”). The Recommendation constitutes a call for Member States to…
Global Trade & Sanctions Law
Framework for Collaboration Between U.S. and UK Sanctions Authorities
Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024, formalizing a framework to govern cooperation including in relation to exchanging information, coordinating investigations, training personnel,…
EU Sanctions Update: The 15th Russia Package Amongst Other Updates
On December 16, 2024, the EU issued its 15th package of sanctions against Russia, new designations under the Belarus sanctions regime, and the first designations under the hybrid threats sanctions regime adopted in October 2024. These updates are summarized below. 1. Asset Freeze Measures Russia (Regulation 269/2014) New designations: 54…
The Treasury Department Finalizes U.S. Outbound Investment Rules
Colleagues Nancy A. Fischer, Matthew R. Rabinowitz, Zachary C. Rozen, Samantha Franks, Erin Kwiatkowski and Marcus Burden recently broke down the key points of a U.S. Department of the Treasury Final Rule that establishes significant new parameters for U.S. outbound investments in sensitive technologies within countries of concern. TAKEAWAYS The Final Rule formalizes a…
BIS Proposes Rules to Protect from Chinese and Russian Connected Vehicle Technology
On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of…
New Enforcement Powers for UK Trade Sanctions Regulators
On September 12, 2024, the UK government published the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (the “Regulations”), granting the UK’s trade sanctions enforcement body, the Office of Trade Sanctions Implementation (OTSI), new implementation and enforcement powers effective from 10 October 2024. The Regulations also grant the Department…
USTR Finalizes Section 301 Tariffs on Chinese Imports with a Focus on Products from “Strategic Sectors”
On September 13, 2024 USTR announced modifications to the tariffs originally imposed under Section 301 of the Trade Act of 1974 to pressure China to eliminate unreasonable policies and practices related to technology transfer and intellectual property protection. The changes reflect a comprehensive review of the duties required by statute.…
Closing the Loophole: Biden Administration Takes Action Against De Minimis Imports from China
On September 12, 2024, the Biden Administration announced a number of new trade-related measures related to imports of Chinese-manufactured goods. This announcement comes as the latest action in the Biden Administration’s efforts to reinforce American manufacturing and supply chains. De Minimis Shipments For some time, bipartisan political pressure has been…
BIS Imposes New Export Controls on Quantum, Semiconductor and Additive Manufacturing Technologies
On September 5, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule imposing significant new export controls on quantum computing, cryocooling systems, semiconductor equipment, and additive manufacturing technologies. These controls are meant to align U.S. regulations with recent regulations adopted by several…
EU’s 14th Package of Sanctions on Russia
On 24 June 2024, the EU adopted its 14th package of sanctions against Russia. The latest measures include: The designation of 116 additional individuals and entities across a number of industries for their responsibility in undermining Ukraine’s territorial integrity, sovereignty, and independence. A limited ban on contracts with Russian state…