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Global Trade & Sanctions Law

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China Year-in-Review: Securing the Battery Supply Chain

During 2023 both Congress and the Biden Administration repeatedly expressed the need to secure critical supply chains, particularly batteries that rely heavily on lithium and critical minerals sourced from China. Concerns have been framed in terms of national security focusing on the danger of relying too heavily on products integral…

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The United States Redesignates the Houthis (Ansarallah) as a Global Terrorist Group

On January 17, 2024, the U.S. Department of State announced the redesignation of the Yemen-based Ansarallah (commonly referred to as the “Houthis”) as a Specially Designated Global Terrorist organization (SDGT). The decision to redesignate Ansarallah comes after several months of attacks by Houthi forces against international maritime vessels in both…

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China Year-in-Review: Technology

In 2023, the United States sharpened its focus on deterring China’s ability to develop advanced technology with the potential to threaten U.S. national security. To do so, the U.S. government has implemented several new restrictions and requirements related to critical technologies. Some of these measures, such as the announcement of…

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U.S. Regulations on China: A Year-in-Review Series

2023 witnessed significant developments from the United States government aimed at countering China’s influence and curbing potential threats to U.S. national security. These developments have spanned legislative and administrative action, shifting long-standing paradigms within export controls, import controls, and sanctions. The Biden Administration is increasingly utilizing these tools as strategic…

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New UK and EU Sanctions introduced against Russia

The United Kingdom introduced new sanctions against Russia on December 14, 2023, with the European Union also adopting its twelfth package of sanctions against Russia on December 18, 2023. The latest UK restrictions include: Import and related restrictions on further categories of iron and steel goods, as well a wide range…

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ISOO Guidance on Facility Security Clearances for Joint Ventures

On October 5, 2023, the National Archives Information Security Oversight Office (ISOO) released a joint notice to provide guidance on facility clearances for joint ventures (JVs) in the National Industrial Security Program (NISP). This guidance addresses the interaction of NISP requirements and an October 16, 2020 Small Business Administration (SBA)…

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DaVinci Payments Settlement with OFAC Reveals Critical Compliance Lessons

On November 6, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $206,213 settlement with Swift Prepaid Solutions, Inc. d/b/a daVinci Payments (daVinci) for apparent violations of sanctions regarding Crimea, Iran, Syria and Cuba. The financial services and payments firm was penalized by OFAC for…

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Closing the Loopholes: Additional Export Controls Issued on Advanced Computing and Semiconductor Manufacturing Items

On November 6, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) held a public briefing to address industry questions concerning the latest export controls on advanced computing and semiconductor manufacturing. The new controls, which BIS announced on October 17, 2023, update existing export restrictions related to…

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U.S. Government Imposes Second Round of Sanctions on Hamas

In their recent client alert, “OFAC Issues New Sanctions Targeting Hamas’s Financing Networks,” colleagues Nancy A. Fischer, Aaron R. Hutman, Matthew R. Rabinowitz, Samantha Franks, Arielle R. Heffez and Erin Kwiatkowski discuss two rounds of sanctions imposed by the U.S. government on Hamas, other terrorist groups and Iranian networks in…

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OMB Final Guidance on Build America, Buy America Act Clarifies, Further Defines

In “OMB Finalizes ‘Build America, Buy America’ Domestic Content Guidance,” colleagues Stephan E. Becker, Marques O. Peterson, Nancy A. Fischer, Moushami P. Joshi, Samantha Franks and Amaris Trozzo examine the finalized “Build America, Buy America” guidance, which clarifies content requirements for non-federal government #infrastructure projects that benefit from federal funding.