On April 24, 2024, President Biden signed HR 815, “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes,” into law (the “National Security Supplemental” or the “NSS”). The National Security Supplemental appropriates
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United States and United Kingdom Take Coordinated Action Against Russian Federation Metals
On April 12, 2024, in a coordinated action the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) in the United States and the Foreign, Commonwealth, and Development Office, HM Treasury, and Department for Business and Trade (“DBT”) in
CFIUS Proposes Important Changes to Foreign Investment Rules with Focus on Enforcement
On April 15, 2024, the U.S. Treasury Department (Treasury), as the Chair of the Committee on Foreign Investment in the United States (CFIUS or the Committee), published a notice of proposed rulemaking (NPRM) “to enhance certain CFIUS procedures and sharpen
OFSI Issues Best Practices Guidance on Maritime Sector Financial Sanctions Compliance
On April 2, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a blog post addressing financial sanctions compliance in the maritime sector. Maritime businesses currently are a particular area of focus for UK sanctions regulators and law enforcement
Export Controls and Sanctions Converge: New BIS Restrictions on SDNs
On March 21, 2024, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule under the U.S. Export Administration Regulations (“EAR”) that imposes new export controls on certain individuals and entities identified on the U.S. Department
Federal Court Finds Corporate Transparency Act Unconstitutional: Navigating Implications for Reporting Companies
On March 1, 2024, the federal district court in the Northern District of Alabama declared in the case of National Small Business United v. Yellen that the Corporate Transparency Act (“CTA”) exceeds the Constitution’s limits on Congress’s power. The court
Biden Administration to Implement New National Security Rules Targeting Personal Data
On February 28, 2024, the Biden administration announced the creation of a new national security regulatory regime that will prohibit or restrict certain transactions involving bulk sensitive US personal data or government-related data and specified “countries of concern.” The Biden
In First of Its Kind Action, Commerce Moves to Regulate Foreign Tech in Vehicles
In a first of its kind action, the US Department of Commerce has begun a rulemaking process to prohibit or impose conditions on certain transactions involving foreign technology used in so-called “connected vehicles” or “CVs,” as defined below for automotive
OFSI Publishes Expanded Guidance on Financial Sanctions Licensing Process and Principles
On February 27, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a number of guidance documents on financial sanctions licensing addressing the process of applying for a licence, as well as the principles applied when making licensing
US Government Imposes New Russia Sanctions, Designating Over 500 Parties and Issuing Interagency Russia Business Advisory
On February 23, 2024, the United States issued a broad set of new Russia-related sanctions and export controls in response to the second anniversary of Russia’s invasion of Ukraine and the February 16, 2024, death of opposition leader, Aleksey Navalny,