The EU is going extraterritorial, and it is doing so through private contract. It is a pretty neat trick.
E(U)xterritoriality of EU Sanctions: The No Russia Clause
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Department of Commerce Initiates Investigation into Chinese-Made “Connected Vehicles”: Potential Prohibitions on Certain Information and Communications Technology and Services
On February 29, 2024, the Biden administration issued a statement addressing the national security risks to the U.S. auto industry directing the Department of Commerce to conduct an investigation into Chinese made “connected vehicles” (CVs).
Guidance to Foreign Companies on Export Controls and Sanctions: Departments of Commerce, Treasury, and Justice Issue Tri-Seal Compliance Note on Foreign Based Persons’ Obligations to Comply with U.S. Sanctions and Export Control Laws
On Wednesday, March 6, 2024, the Department of Commerce, Department of the Treasury and Department of Justice issued another Tri-seal Compliance Note, focusing this time on the obligations of foreign based persons complying with U.S. sanctions and export control
Protective Packaging: The EU’s Economic Security Package Changes the Landscape in Global Technology Controls
The EU plans to step up controls on its home-grown technology. That is the short version.
The EU Commission Gets Serious About FDI Screening
As part of its European Economic Security Package, the European Commission (‘Commission’) has recently proposed a number of legislative proposals and White Papers intended to better protect Europe’s strategic interests. We have covered the wider initiative here.
Should You Be Concerned About Foreign Entities of Concern?
Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to benefit from those grants
New Russia Sanctions Intensify Pressure on Banks Worldwide
On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated that the Office of Foreign Assets Control (OFAC) will take
Carrot and Stick Export Controls: U.S. Export Controls Give Benefits to Allies
Export controls are the manifestation of foreign, economic, and national security policy, and the implementation of policy requires dynamic adjustment, a back-and-forth, a balance. So, on December 7, 2023[1], amid the tightening of new semiconductor regulations, BIS
The Semiconductor Moment
- Semiconductors are the only commodity that are as ubiquitous and as heavily regulated.
- Semiconductors are unique: nothing so common is as tightly controlled, and nothing so tightly controlled is as common.
- But this puts the industry in an extremely complex
Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History
On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger comprehensive settlement with the Department of