On August 31, 2023, OFSI made its first use of the disclosure enforcement power granted to it pursuant to the Economic Crime (Transparency and Enforcement) Act 2022 (“ECA”) in relation to a case involving Wise Payments Limited (“Wise”) making funds
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Critical Tornado Cash Developments Have Significant Implications for DeFi AML and Sanctions Compliance
After months of anticipation, a federal judge has finally ruled in the closely watched case of Joseph Van Loon, et al. v. Department of Treasury, et al. This important case addressed challenges to the US Department of the Treasury’s Office
Critical Tornado Cash Developments Have Significant Implications for DeFi AML and Sanctions Compliance
After months of anticipation, a federal judge has finally ruled in the closely watched case of Joseph Van Loon, et al. v. Department of Treasury, et al. This important case addressed challenges to the US Department of the Treasury’s Office
Amid Growing Trade Tensions, U.S. Imposes Unprecedented Restrictions on Outbound Investments to China
On August 9, 2023, the Biden administration issued a much-anticipated Executive Order establishing a new regime to limit certain U.S. investments in key Chinese technology sectors to prevent the financing of Chinese military advancement. The order, once implemented via regulation,
100% AI-Generated Works Cannot Receive A Copyright (But Works Created Jointly By Humans And AI May Be Copyrightable)
A Federal Court ruled that works that are entirely created by artificial intelligence (“AI”) systems cannot receive a copyright under United States law. Contrary to how this decision has been reported in news summaries, the case was decided on a
BIS Promulgates CCL Changes Based on Nuclear Supplier Group Commitments
Effective August 18, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) issued amendments to the Commerce Control List (CCL) (15 CFR Part 774) of the Export Administration Regulations (EAR) to formalize changes based on
OFAC Sanctions Former Governor of Lebanon Central Bank and Associates
On August 10, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), in coordination in the United Kingdom and Canada, designated the former governor of Lebanon’s central bank, Riad Salameh (“Salameh”) and four close associates,
Key Takeaways from the 2022 CFIUS Annual Report
On July 31, 2023, the Committee on Foreign Investment in the United States (CFIUS) released its Annual Report to Congress for Calendar Year 2022. CFIUS is the inter-agency body charged with conducting national security reviews for certain foreign investments
Is PURPA Relevant to Non-PUPRA State Procurement Mandates? Presumably Not, But There Is a Lesson To Be Learned From the Recent Allco Challenge
As noted in the most recent blog post, a challenge by Allco Finance Limited (Allco) to the Massachusetts Department of Public Utilities’ (DPU) and the Massachusetts Department of Energy Resources’ (DOER) (Massachusetts Agencies) implementation of Massachusetts’ seven-year old legislation
Mandatory and Not So Mandatory Wholesale Purchases at State-Set Rates: Allco Leans In
The easiest means for a state to provide a subsidy to a preferred generation/resource type or class is to mandate purchases from that class at state-mandated rates. The typical reaction of a FERC attorney to such a claim should be,