On November 1, 2017, the Department of Commerce’s Bureau of Industry and Security (BIS) introduced clarifications to the Export Administrative Regulations (EAR) for the use of license exception “Governments, International Organizations, International Inspections under Chemical Weapons Convention, and the International Space Station” (GOV), and license exception “Strategic Trade Authorization” (STA).…
Global Trade & Sanctions Law
Russia Sanctions under CAATSA – U.S. Updates Rules and Provides Guidance on Enforcement
This week, the U.S. government took several steps to implement sections of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), with implications for Russia-related sanctions and their enforcement. On October 27, 2017, the Department of State (DoS) published guidance on sanctions with respect to Russia’s Defense and Intelligence…
House Passes Bills Targeting Iran’s Missile Program and Hizballah
On October 25, 2017, the U.S. House of Representatives passed three bills and a resolution in response to Iran’s ballistic missile program and threats posed by Hizballah. Notably, neither the bills nor the resolution would directly affect U.S. obligations in relation to the Iran Nuclear Agreement (Joint Comprehensive Plan of…
Another Market Opens: U.S. Revokes Sudanese Sanctions Program Though Important Limitations Remain in Place
Effective October 12, 2017, the Sudanese Sanctions Regulations (SSR) have been revoked in recognition of the Government of Sudan’s (GOS) sustained positive actions in stopping conflict and improving humanitarian access in Sudan. This latest action makes permanent the general license issued in January 2017. However, Sudan remains designated as a…
President Trump Issues Executive Order Blocking Proposed Acquisition of Lattice Semiconductor
President Trump issued an Executive Order prohibiting the proposed acquisition of Lattice Semiconductor (Lattice) by a Chinese consortium known as Canyon Bridge. Lattice is a semiconductor company primarily manufacturing programmable logic devices. The Executive Order prohibits the proposed acquisition and any substantially equivalent transaction, and requires the parties to permanently abandon…
FinCEN Expands Its GTOs
On Aug. 22, 2017, the Financial Crimes Enforcement Network (FinCEN) announced an expansion of its Geographic Targeting Orders (GTO) that require the identification by U.S. title insurance companies of the natural persons behind shell companies used to buy high-end residential real estate. On Gravel2Gavel, colleague Christine Scheuneman provides a number…
New Executive Order Imposes Further Sanctions on Venezuela
Today, President Trump issued an Executive Order (E.O.) providing for sanctions against the Government of Venezuela. The sanctions are structured similar to existing sectoral sanctions on the Russian petroleum sector and target financial transactions with the Government of Venezuela. The new E.O. targets certain long-term financial transactions with the Government…
Three Birds with One Stone: New Russia, North Korea and Iran Sanctions
On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act (CAATSA), which strengthened U.S. sanctions on Russia, North Korea and Iran. CAATSA had been passed by overwhelming “veto-proof” majorities of Congress and President Trump signed the bill while expressing reservations concerning the limitations it…
OFAC Updates FAQs on the Cuba Sanctions Program
On June 16, 2017, President Trump issued a National Security Presidential Memorandum on Strengthening the Policy of the United States Toward Cuba, which began the process to alter some aspects of U.S. policy toward Cuba. [See prior blog post here]. On July 25, 2017, OFAC updated its Cuba FAQs to…
Senate Minority Leader Urges President Trump to Suspend Chinese Acquisitions of U.S. Companies
Recent public reports indicate Sen. Chuck Schumer (D-NY), the Senate Democratic Leader, has authored a letter to President Trump requesting the President order the Committee on Foreign Investment in the United States (CFIUS) to suspend the approval of all covered transactions by Chinese entities. Sen. Schumer explains that such action…