On November 7, 2024, the Committee on Foreign Investment in the United States (CFIUS), in coordination with the Department of Defense (DoD), issued a Final Rule that expanded its ability to review certain real estate transactions by foreign persons near more than 60 military bases and installations across 30 states. In addition, CFIUS’s jurisdiction over
Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
DHS Updates UFLPA Entity List with Additional Chinese Textile Companies
On October 31, 2024, the Department of Homeland Security (DHS) announced that effective November 1, 2024, four textile Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be facilities and entities that source material from the Xinjiang Uyghur Autonomous Region or from persons working with the…
BIS, DDTC Publish a Series of Rules to Modernize U.S. Space-Related Export Controls
On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently…
BIS Adds 26 Companies to the Entity List
On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls…
OFAC Expands Sanctions on Iran for Missile Attack on Israel
On October 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was expanding sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel. The Secretary of the Treasury has identified the petroleum and petrochemical sectors of the Iranian economy pursuant to a…
BIS Enhances Its Enforcement Discretion: Final Rule Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines
- The final rule took effect September 16. It codifies the series of “policy memoranda” BIS began issuing in 2022 to clarify the agency’s evolving attitude toward voluntary self-disclosures, which in turn aimed to encourage companies, universities and individuals to engage in the process after believing a violation of the Export Administration Regulations, or
OFAC Again Extends Authorizations Under Russia General License 13
On September 30, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13K, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software
- Proposed rule would prohibit the import and sale of connected vehicles equipped with certain hardware or software developed, manufactured, or supplied by Chinese or Russian-affiliated entities.
- Proposed rule would also prohibit the sale of connected vehicles manufactured by Chinese or Russian OEMs.
- Prohibitions would take effect between 2027 and 2030.
- If implemented, manufacturers
OFAC Issues New & Updated Russia-Related General Licenses in Connection with Recent Designations
On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election.
OFAC Issues Final Rule on Procedures Related to Blocking Property
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. The rule is effective as of September 17, 2024.
The new rule aims to clarify OFAC’s process for issuing orders that block…
