China and the United States continue to move towards finalizing a “phase one” trade deal. Speaking to the Economic Club of New York, President Trump stated that the United States is “close” to a deal and that it “could happen soon.” The President was also quick to note that he would only accept a deal

On November 1, 2019, the World Trade Organization (WTO) authorized China to suspend $3.579 billion in trade concessions to the United States, roughly half the $7 billion amount China had requested. The Arbitrator’s Decision stems from a complaint originally lodged by China in 2013 regarding the use of certain methodologies in antidumping investigations on Chinese

On October 22, 2019, the Office of Foreign Assets Control (OFAC) issued General License No. 2G authorizing U.S. persons to engage in transactions involving nine companies: Belarusian Oil Trade House, Belneftekhim, Belneftekhim USA, Inc., Belshina OAO, Grodno Azot OAO, Grodno Khimvolokno OAO, Lakokraska OAO, Naftan OAO, and Polotsk Steklovolokno OAO. Executive Order 13405 had previously

Yesterday, the Office of Foreign Assets Control (OFAC) issued General License No. 8D, authorizing U.S. persons to engage in transactions and activities involving Petroleos de Venezuela, S.A. (PdVSA) that are ordinarily incident and necessary to the maintenance of operations, contracts, and other agreements involving Chevron, Halliburton, Schlumberger Limited, Baker Hughes, and Weatherford International in

On Friday, October 11, 2019, President Trump announced that a “phase one” agreement had been reached with China. Most notably, the U.S. agreed to suspend its plan to increase tariffs from 25% to 30% on $250 billion in Chinese goods, which had been scheduled for October 15. In return, China has agreed to purchase between

On Monday, October 14, 2019, President Trump announced that the U.S. will increase steel tariffs to 50% as a sanction against Turkey’s military advance into Syria last week.  The steel tariffs were originally imposed at 25% under Section 232 of the Trade Expansion Act of 1962 in March, 2018.  In August, 2018, President Trump raised

On October 7, USTR Robert Lighthizer and Ambassador Shinsuke Sugiyama signed both the U.S.-Japan Digital Trade Agreement and the U.S.-Japan Trade Agreement. President Trump praised the agreements, stating “[t]hese two deals represent a tremendous victory for both of our nations.  They will create countless jobs, expand investment and

A recent suit filed by the U.S. Department of Justice (DOJ) for the forfeiture of nearly $2 million highlights the broad extraterritorial reach of U.S. sanctions laws.  On June 14, DOJ filed a complaint to seize funds associated with transactions between several Chinese companies, including Mingzheng International Trading Limited (Mingzheng).  Mingzheng and the other companies had been set up as a front and were conducting transactions in U.S. dollars on behalf of North Korea’s Foreign Trade Bank (FTB), a blacklisted Specially Designated National (SDN).  The case has two noteworthy lessons, with the latter lesson hopefully more relevant to your company:

Lesson One: Don’t launder money for North Korean SDNs engaged in proliferation schemes.  If you want to know more about how North Korea attempts to launder funds, check out this detailed and fascinating report on the topic.

Lesson Two: If you conduct a transaction in U.S. dollars, even if all other aspects of the transaction occur outside of the United States, the U.S. government will likely claim jurisdiction over the transaction.
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