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International Regulatory Enforcement

U.S. House of Representatives Passes Bill That Would Impose “Mini-Embargo” and Disclosure of Goods from Xinjiang
Last week, the U.S. House of Representatives considered two bills that would place broad restrictions on products from the Xinjiang Uyghur Autonomous Region (“XUAR”) of China, and would require publicly listed companies to disclose if they trade in products manufactured using forced labor from the region.
State and Commerce Departments Take New Action on 24 Chinese Companies
On August 26 2020, the United States Government announced visa restrictions on Chinese individuals and imposed sanctions on 24 Chinese companies for their alleged activities related to the PRC’s territorial claims in the South China Sea. The Department of Commerce added those companies to the Entity List, a list maintained by the Bureau of Industry and Security (BIS) that identifies persons believed to be involved in, or pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States. Separately, the Department of State issued visa restrictions on executives (and their family members) believed to be involved in the conduct at issue.
Nine Things You Need to Know About the Trump Administration Sanctions Against TikTok and WeChat
On Thursday, August 6, 2020, the Trump Administration took long-rumored action against the popular social media apps, TikTok and WeChat, in the forms of two executive orders. The orders largely prohibit persons or property subject to U.S. jurisdiction from transactions with the China-based owners of the apps, escalating tensions between U.S. and China and causing wide speculation on their scope and impacts. Because these two executive orders have many provisions requiring interpretation and guidance, we seek to answer nine frequently asked questions about this latest executive action by the Trump Administration.
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
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