International Compliance Blog

  On April 15, Steptoe associate Peter Jeydel commented about recent CFIUS developments on Steptoe’s Cyberlaw Podcast, including the forced divestment of a Russian investor out of Cofense, a US cybersecurity company, and an unprecedented $1M fine for failure to implement a mitigation agreement. To listen to Pete’s comments, please press play above. To listen to the entire episode, please visit Steptoe’s Cyberlaw Podcast on the Steptoe Cyberblog.…
Steptoe’s Brian Egan and Peter Jeydel authored a Feature Comment in The Government Contractor, a Thomson Reuters publication, discussing the provisions of the Export Control Reform Act of 2018 that are most likely to have a lasting impact on industry. US and international companies should take careful note of the enduring changes to export controls enforcement set out by this statute and prepare for its consequences, including possible changes to China-focused export controls. To…
Yesterday, Secretary of State Mike Pompeo announced his intent to designate Iran’s Islamic Revolutionary Guard Corps (IRGC) as a Foreign Terrorist Organization (FTO), noting that this is the first time the US government has designated part of another government as an FTO. The announcement explains: “This action underscores that the Iranian regime’s use of terrorism makes it fundamentally different from any other government. Iran employs terrorism as a central tool of its statecraft; it is…
In recent weeks, Reuters and other media outlets have reported that Beijing Kunlun Tech Co., Ltd. (Kunlun), the owner of the popular gay dating app Grindr, was seeking to sell the app due to concerns raised by the Committee on Foreign Investment in the United States (CFIUS). CFIUS is the interagency US government committee with authority to review foreign acquisitions of, and certain investments in, US companies that present US national security concerns. According to…
Lost in the recent US-China trade headlines about tariffs, indictments, trade secrets theft, cyber espionage and other matters is a potentially important development lurking in last year’s US export controls statute. Essentially, Congress has directed the Executive Branch to review the current scope of US export controls on China and other countries subject to arms embargoes, and to implement changes to address any vulnerabilities. This review is supposed to be done and any regulatory changes implemented by…
Steptoe’s International Trade group has put together a helpful guide to the new NAFTA (the US-Mexico-Canada Agreement (USMCA)). The Agreement must still go through ratification and implementation processes in all three countries before it can enter into force. In the coming weeks, the Trump Administration will submit legislation to Congress to implement the USMCA. Before a vote can be taken in the United States, however, the Administration will first need to resolve concerns and objections…
This Tuesday, March 19, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on CVG Compañía General de Minería de Venezuela CA (Minerven), the Venezuelan state-run ferrous metals mining company, and its President, Adrian Antonio Perdomo Mata. The addition of Minerven and Mr. Perdomo Mata to the OFAC Specially Designated Nationals and Blocked Persons list (SDN List) follows the imposition of the same sanctions announced against PdVSA (Petróleos de Venezuela, S.A.)…
Next week, the World Trade Organization (WTO) will consider Venezuela’s request for the establishment of a panel to decide whether US sanctions affecting Venezuela violate international trade law. In December, Venezuela filed its second ever complaint at the World Trade Organization challenging US sanctions. Specifically, Venezuela claimed that the US imposed “coercive trade-restrictive measures” in an attempt to isolate Venezuela economically. These measures included “certain US laws and regulations relating to goods of Venezuelan origin,…
US government enforcement of the Foreign Corrupt Practices Act (FCPA) remained robust in 2018, and the trend of increasing multi-jurisdictional cooperation and enforcement continued throughout the year. In the United States, the 33 combined individual and corporate FCPA enforcement actions concluded by the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in 2018 were largely consistent with the average number of enforcement actions brought over the last seven years. The US $2.91…