International Compliance Blog

Following months of hearings and other deliberations, Congress passed, and President Trump signed into law on August 13, 2018, the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). FIRRMA is the first update to the Committee on Foreign Investment in the United States (CFIUS) in over a decade and will significantly expand the jurisdiction of the Committee and make other notable changes to its rules. A text of the final version of FIRRMA (Sections…
In response to President Trump’s Executive Order re-imposing certain Iran-related sanctions, summarized in our recent post, the EU has expanded the scope of the EU Blocking Statute to cover certain US Iran-focused sanctions.  On August 7, immediately following the US government’s re-imposition of certain Iran-related sanctions, the Commission Delegated Regulation (EU) 2018/1100 amending the annex to the EU Blocking Statute was published in the EU Official Journal and entered into force. In addition to…
On August 8, 2018, the US State Department announced that it would be imposing new sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).  The new sanctions are in response to a determination by the US government that the Russian government was behind the recent use of a nerve agent in the United Kingdom against two UK citizens.  The CBW Act requires the imposition of…
President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions commitments under the JCPOA.  Some of the re-imposed sanctions will be effective tomorrow, August 7; others will come back into…
Earlier this week, negotiators from the House and Senate reached agreement on what will very likely be the final text of the Foreign Investment Risk Review Modernization Act (FIRRMA), which will be part of the National Defense Authorization Act for Fiscal Year 2019 (NDAA). FIRRMA seeks to overhaul the Committee on Foreign Investment in the United States (CFIUS) by expanding the scope of the committee’s jurisdiction and closing certain “loopholes,” among other revisions.  A text…
Since President Trump’s announcement, on May 8, that the United States would withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose previously lifted sanctions against Iran, the remaining JCPOA signatories have been scrambling to save the agreement. On June 4, officials from the UK, Germany, France, and the EU sent a letter to Secretary of State Mike Pompeo and Secretary of the Treasury Steven Mnuchin seeking a number of exemptions to US…
The US Commerce Department’s Bureau of Industry and Security (BIS) terminated the ZTE Denial Order, effective today.  As a result, ZTE is no longer subject to any specific US export control restrictions (except for ZTE Parsian, an Iranian affiliate that remains on the BIS Entity List).  ZTE still faces a series of stringent requirements that will last 10 years, pursuant to its settlement with BIS, and any failure to comply could lead to a…
On June 26, 2018, the US Supreme Court upheld the Trump Administration’s third travel ban and, more significantly, affirmed the president’s broad authority to restrict immigration by Executive Order (EO). In Trump v. Hawaii, the Court found that the EO was within the president’s authority under an Immigration and Nationality Act (INA) provision that gives the president the ability to restrict the entry of foreign nationals into the US whenever the president finds that such…
The ambitious CFIUS reform bill introduced in November 2017, the Foreign Investment Risk Review Modernization Act (FIRRMA), has recently received significant congressional attention and appears likely to become law this year, with some revisions from the version introduced last year. On June 18, 2018, the Senate passed its version of FIRRMA as Title XVII of the National Defense Authorization Act of 2019 (H.R. 5515). On June 26, 2018, the House passed its version…
Effective yesterday, as part of the President’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the Office of Foreign Assets Control (OFAC) revoked several general authorizations that had been issued as part of the JCPOA, and amended the Iranian Transactions and Sanctions Regulations (ITSR) to implement “wind down” periods for persons who had previously relied on these authorizations.   In addition, OFAC updated its Frequently Asked Questions (FAQs) providing guidance on the JCPOA…