2020

On October 1, 2020, the Department of the Treasury issued two related advisories to assist U.S. companies in efforts to combat ransomware scams and attacks. In addition to offering guidance, the advisories note that anti-money laundering and economic sanctions regulations implemented and enforced by Treasury’s Office of Terrorism and Financial Intelligence may be triggered by…

In a series of actions this week, the Department of the Treasury moved to implement regulations to enforce sanctions related to actions of the International Criminal Court (ICC). Almost immediately, however, President Trump’s executive order and the regulations were challenged in court.

ICC-Related Executive Order and Regulations

On June 11, 2020, President Trump issued Executive…

The Office of the U.S. Trade Representative (USTR) has issued two Federal Register notices announcing the extension of a limited number of product exclusions from the Section 301 tariffs for imports from China appearing on List 1 (products from China with an annual trade value of $34 billion) and List 2 (products from China with…

On September 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Syrian individuals and 13 entities, placing them on the Specially Designated Nationals and Blocked Persons (SDN) List. These persons and entities are associated with the Fourth Division of the Syrian Arab Army, the Syrian General Intelligence Directorate and…

On September 30, President Donald Trump issued an executive order (EO) declaring a national emergency to address “the threat posed by our Nation’s undue reliance on critical minerals, in processed or unprocessed form, from foreign adversaries.” In a message to Congress, the president stated that a “strong America cannot be dependent on imports from foreign…

On September 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice reopening the public comment period for its Section 232 national security investigation of imports of vanadium. BIS initially opened the investigation into vanadium imports on June 2, 2020 (see Update of June 3, 2020) as…

On September 24, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Federal Register notice amending the Cuban Assets Control Regulations (CACR) in order “to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.” The changes will restrict: (1) lodging at certain properties in Cuba;…

On September 24, 2020, the U.S. Department of Commerce published a Federal Register notice listing prohibited transactions with ByteDance Ltd. and its subsidiaries including TikTok, Inc., pursuant to President Trump’s August 6, 2020 Executive Order declaring TikTok a national security threat and directing Commerce to define the scope of prohibited “transactions” with TikTok by September…

On September 18, 2020, the U.S. Department of Commerce announced prohibitions on transactions relating to the mobile applications WeChat and TikTok in order to “safeguard the national security of the United States” that were to become effective on September 20 and November 12, 2020. This announcement followed President Trump’s August 6, 2020 executive orders declaring…

On September 19, 2020, the United States announced that virtually all United Nations (UN) sanctions on Iran were being re-imposed. President Donald Trump and Secretary of State Mike Pompeo have taken the position that the United States can trigger the “snapback” provisions of UN sanctions under UN Security Council resolution 2231 pursuant to the Joint…