Key Notes:

  • U.S. sanctions regulations require persons subject to U.S. jurisdiction to file initial and annual reports on blocked property and rejected transactions with OFAC.
  • Annual reports of property blocked from July 1, 2020 to June 30, 2021 must be submitted by September 30, 2021.
  • There is no annual reporting requirement for rejected transactions.


On August 9, 2021, the White House issued a new Executive Order (EO), “Blocking Property of Additional Persons Contributing to the Situation in Belarus,” which expands existing U.S. sanctions against Belarus to target various sectors. The Treasury Department’s Office of Foreign Assets Control (OFAC) also issued a host of new designations to the Specially Designated

Over the past year, there have been many legal and regulatory developments that critically impacted trade and investments between China and the United States. Given the broad impact and frequency of these changes, we are providing quarterly consolidated updates on key changes. For recent past developments, please also see our March 2021 update.


The Committee on Foreign Investment in the United States (CFIUS or the “Committee”), an inter-agency committee headed by the Department of the Treasury, has released its 2020 Annual Report to Congress (Report). CFIUS is authorized to review transactions that could result in the control of U.S. businesses by foreign persons or companies, as well as

Key Notes:

  • On July 13, the U.S. government released an updated version of the Xinjiang Supply Chain Business Advisory advising U.S. companies of the widespread, PRC-government sponsored forced labor and intrusive surveillance practices targeting ethnic and religious minorities in Xinjiang.
  • The Advisory urges U.S. companies with supply chains, ventures or investments connected to Xinjiang to

On June 15, 2021, the United States and the European Union (EU) announced a “cooperative framework” to resolve their decades-long World Trade Organization (WTO) dispute involving alleged subsidies in the large civil aircraft industry supporting both Boeing and Airbus. U.S. Trade Representative Katherine Tai stated, “Our goal was clear – to forge a new, cooperative

Key Notes:

  • Proposed rule would allow persons working under a long-term contract to be considered “regular employees” under the International Traffic in Arms Regulations (ITAR) even if they work remotely.
  • Remote work would be permitted so long as people were not working in Belarus, Burma, China, Cuba, Iran, North Korea, Russia, Syria or Venezuela, or

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (EO). The EO supersedes the executive orders targeting “Communist Chinese Military Companies” that the Trump administration issued. Specifically, it revises Sections 1 through 5 of Executive Order 13959