The Office of Foreign Assets Control (“OFAC”) recently announced a settlement agreement with Danfoss A/S (“Danfoss” or “the company”) in response to allegations that Danfoss directed its customers in Iran, Syria, and Sudan to make payments through third-party agents to Danfoss’s bank account at the branch of a U.S. financial institution located in the United
Initial Restructuring of the International Traffic in Arms Regulations
As part of a comprehensive streamlining effort, the U.S. State Department’s Directorate of Defense Trade Controls (DDTC) issued an interim final rule that reorganizes and restructures Part 120 of the International Traffic in Arms Regulations (ITAR). This action marks the initial stage of the DDTC’s effort to restructure and consolidate the ITAR through a series
CFIUS Issues New Enforcement and Penalty Guidance
On October 20, the Committee on Foreign Investment in the United States (CFIUS or the Committee) issued a press release laying out new guidance to provide clarity about how the Committee assesses violations of the laws and regulations that govern transaction parties, including potential breaches of CFIUS mitigation agreements.
Penalties are possible for the following
Biden Administration Issues Executive Order Defining Additional National Security Considerations for CFIUS
On September 15, President Biden signed an Executive Order (EO) with the first ever formal Presidential direction to the Committee on Foreign Investment in the United States (CFIUS or the Committee). The EO emphasizes the risks that the Committee should consider when reviewing covered foreign company purchases of U.S. businesses. The EO is intended reemphasize
Commerce Department Significantly Expands Export Controls on Russia and Belarus; Limits Exceptions for Belarusian Aircraft
In a rule change that was effective April 8, 2022, but communicated on April 11, 2022 the Commerce Department’s Bureau of Industry and Security (BIS) expanded coverage of export controls on Russia and Belarus to include any item with an Export Control Classification Number (ECCN). Prior controls applied to items in Commerce Control List (CCL)
Summary of Sanctions Imposed on Russia This Week (March 11, 2022)
It has been almost three weeks since the U.S. and its allies began imposing serious new sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. This post summarizes the state of affairs as of Friday, March 11, 2022.
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More Sanctions on Russia: Import Bans, Revocation of MFN Status, Luxury Goods Ban, USD Ban, Other Measures
In coordination with the European Union and G7 countries, the United States announced a raft of new sanctions and trade control measures targeting Russia today in response to the ongoing war in Ukraine. The new measures include:
- The planned revocation of Russia’s Most Favored-Nation status, which is likely to substantially increase duties on many imports
Summary of Sanctions Imposed on Russia This Week (March 4, 2022)
Over the last two weeks, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia and Belarus in response to Russia’s invasion of Ukraine. Additional sanctions measures are likely in response to the very fluid situation in Ukraine.
This post summarizes the state of affairs
Summary of the Wide-Ranging Sanctions Imposed on Russia This Week
This week, the United States, European Union, and allied countries imposed a broad range of sanctions and export control restrictions on Russia in response to Russia’s invasion of Ukraine. We expect Western countries to implement additional measures in the coming days and weeks in response to the very fluid situation in Ukraine.
This post summarizes
Commerce Department Issues New Export Controls on Russia in Response to the Invasion of Ukraine
As part of a package of new sanctions on Russia that are effective February 24, 2022, the United States imposed a series of significant new export control measures on exports of many products, software and technology to Russia. The Bureau of Industry & Security (BIS), the bureau at the Commerce Department that administers U.S. “dual