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International Regulatory Enforcement

U.S. Department of Commerce Issues Final Rule Suspending Certain Preferential License Exceptions for Hong Kong
In the latest development in the continuing evolution of U.S.-China economic relations, the U.S. Department of Commerce on July 30, 2020 issued its Final Rule suspending the availability of all License Exceptions for the Hong Kong Special Administrative Region (“SAR”) that provide differential treatment as compared to those available to the People’s Republic of China (“PRC”). The Final Rule formalizes the Department of Commerce Bureau of Industry and Security’s (“BIS”) June 30, 2020 announcement that License Exceptions are no longer available to the extent they provided the Hong Kong SAR differential treatment as compared to the PRC.
UK and EU Financial Sanctions Regimes Likely to Diverge Post-Brexit
The looming end of the Brexit transition period will have practical implications for the UK’s financial sanctions regimes. This is because financial sanctions that apply in the UK today are derived from EU regulations. These will cease to apply after 31 December 2020.
U.S. Corporate Regulation Increases Amidst U.S.-China Tensions
As diplomatic tensions between Washington and Beijing rise, there is a corresponding increase in U.S. and Chinese regulation of corporate economic activity between the two nations.
New Targeted and Secondary Sanctions Regime For Hong Kong and the PRC
In one of the latest developments in the fast-changing economic and foreign policy relationship between the United States and the People’s Republic of China (“PRC”), the Trump Administration on July 14, 2020 issued an executive order implementing economic sanctions against foreign persons who undermine Hong Kong’s autonomy. The President also signed the Hong Kong Autonomy Act (HKAA) into law on the same day.
U.S. Increases Sanctions on Iran as Tensions Escalate
On Friday, January 10, the Trump Administration increased the stakes for non-U.S. companies seeking to do business with Iran, as tensions between the two countries escalate.
OFAC’s Mixed Signals Lead to Exxon Victory in District Court
Jason Fiebig, Jeremy Steed, Christina Ferma, Thomas Jordan
A One-Two Punch: The U.S. Government Hits China's Technology Sector
The United States Government took two actions on Wednesday that indicated increased pressure and restrictions on the Chinese telecommunications sector. First, President Trump declared a national emergency that will prevent U.S. companies from transacting with foreign information and communication technology companies that the U.S. government deems to be a national security threat. Second, the U.S. Department of Commerce announced it would place Huawei and 68 affiliates on the Entity List, effectively prohibiting the supply to Huawei of any U.S. goods or technology
President Trump Withdraws From Iran Deal - Six Key Takeaways
On May 8, 2018, President Donald Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) with Iran. President Trump's unilateral decision to withdrawal from the agreement puts the fate of the JCPOA in jeopardy. The impact on U.S. foreign policy will be profound, but, more immediately, the President's decision triggers an end to U.S. sanctions relief under the JCPOA and re-imposes many sanctions prior to January 2016. The implications are far reaching. We identify six key takeaways for U.S. and global businesses.
Italy Introduces New Measures to Simplify Dual-Use Export Transactions and Sets the Sanctions Related to Trade Embargoes and Proliferating Materials
Italy introduced new comprehensive measures to organize and simplify the authorization procedures on dual-use items and exported technologies. The Government has also established the sanctions applicable to infringements of the rules on dual-use and not listed items, as well as items covered by anti-torture measures and EU sanctions.