On January 3, 2025, President Joseph Biden issued a Presidential Order blocking an approximately $15 billion proposed acquisition by Nippon Steel Corporation (Nippon Steel) of Japan to purchase Pittsburgh-based United States Steel Corporation (U.S. Steel). Explaining that the proposed acquisition might result in actions that threaten to impair the national security of the United States
OFAC Issues General License Allowing Transactions Involving Gazprombank Related to Civil Nuclear Energy
On December 19, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 115 to generally authorize transactions involving Gazprombank that are related to civil nuclear energy. After sanctioning Gazprombank in November 2024 in order to further limit Russia’s access the international financial system (see Thompson Hine Update
BIS Seeks to Further Strengthen Export Controls Targeting China’s Advanced Semiconductor Industry
On December 2, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued two new rulemakings in an ongoing effort to “further impair [China’s] capability to produce advanced-node semiconductors that can be used in the next generation of advanced weapon systems and in artificial intelligence (AI) and advanced computing, which have significant military
USTR Increases Tariffs Under Section 301 Trade Action on China for Tungsten Products, Wafers, and Polysilicon
On December 11, 2024, the Office of the United States Trade Representative (USTR) announced tariff increases under Section 301 of the Trade Act of 1974 for imports from China of certain tungsten products, wafers, and polysilicon. Beginning on January 1, 2025, the rates for solar wafers and polysilicon will increase to 50%, and the rates
OFAC Further Expands Sanctions on Iran for Missile Attack on Israel and Renewed Nuclear Escalations
On December 3, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was “intensifying pressure” on Iran’s petroleum and petrochemical sectors by imposing sanctions on 35 entities and vessels “that play a critical role in transporting illicit Iranian petroleum to foreign markets.” This action identifies and imposes further sanctions
BIS Announces New Controls on Exports to Pakistan
On November 25, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced new export controls targeting Pakistan to address concerns about the diversion of certain items to unauthorized end uses or end users, particularly those on the Entity List. The final rule, effective November 25, 2024, imposes new licensing requirements
DHS Updates UFLPA Entity List with Additional Chinese Companies
On November 22, 2024, the Department of Homeland Security (DHS) announced the addition of 29 companies based in China to the Uyghur Forced Labor Prevention Act (UFLPA) Entity List, bringing the total number of entities on the UFLPA Entity List to 107. The newly identified and listed companies are involved in (i) electronic materials and
OFAC Sanctions Gazprombank and Further Limits Russia’s Access to International Financial System
On November 21, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Gazprombank, more than 50 internationally connected small-to-medium Russian banks, more than 40 Russian securities registrars, and 15 Russian finance officials. Treasury Secretary Janet Yellen stated that these sanctions target “Russia’s largest remaining non-designated bank, as well as dozens of
CFIUS Issues Final Rule Enhancing Enforcement and Penalty Regulations
On November 18, 2024, the Department of the Treasury (Treasury), as Chair of the interagency Committee on Foreign Investment in the United States (CFIUS), issued a final rule to enhance certain CFIUS procedures and sharpen its penalty and enforcement authorities. It revises certain provisions of the CFIUS regulations, 31 C.F.R. Parts 800 and 802, pertaining
Final Rule Issued on Outbound U.S. Investments in National Security-Related Technologies in Countries of Concern
The Department of the Treasury has issued a Final Rule to implement Executive Order 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern.” This Final Rule provides the operative regulations and a detailed explanatory discussion regarding the intent and application of these new U.S.