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On February 3, 2023, U.S. Customs and Border Patrol (CBP) issued a determination in the Federal Register providing notice that it has determined that palm oil and various derivatives thereof “are no longer being mined, produced, or manufactured wholly or in part with the use of convict, forced, or indentured labor by the Sime Darby

On January 27, 2023, U.S. Secretary of State Antony Blinken and U.S. Trade Representative Katherine Tai hosted the initial ministerial for the Americas Partnership for Economic Prosperity (APEP), a regional framework for cooperation to promote inclusive economic growth and strengthen competitiveness. The APEP consists of the United States, Barbados, Canada, Chile, Colombia, Costa Rica, the

On January 18, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule extending export controls currently in place for China on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items to the Macau Special Administrative Region of China (“Macau”). While China

As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2023. 

Annual Self-Classification Report

The self-classification report covers less sensitive items covered under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.

On January 7, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5J, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO

On January 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three amended General Licenses (GLs) regarding the continued authorization of certain limited activities in Russia or involving Russian entities. 

  • Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,

On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as

Key Notes:

  • Real estate projects may be subject to CFIUS national security review if close to sensitive locations.
  • Proactive planning can mitigate transaction delays.
  • Security concerns may be broader than CFIUS regulatory issues and merit multi-tiered government and public outreach.

The Committee on Foreign Investment in the United States (CFIUS) recently reviewed a proposed real

Effective December 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 36 Chinse entities to BIS’s Entity List. These additions are intended to further restrict China’s “ability to leverage artificial intelligence, advanced computing, and other powerful, commercially available technologies for military modernization and human rights abuses,” according