Author

Alison J. Stafford Powell (US)

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On Friday, May 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and Switzerland’s State Secretariat for Economic Affairs (“SECO”) issued a joint Memorandum of Understanding (“MOU”) in regard to the United States and Switzerland’s commitment to collaborate and share information related to sanctions and enforcement which was signed on May 9, 2025. The notice is published on OFAC’s website here. The MOU provides that information sharing between the United States and…

On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,”…

On January 14, 2025, President Biden took action towards rescinding Cuba’s designation as a State Sponsor of Terrorism (“SST”) and to remove restrictions on financial transactions with certain Cuban parties by issuing to Congress a Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism (“Certification”) and National Security Memorandum 29 (“NSM-29”) revoking a past National Security Presidential Memorandum related to Cuba that had been issued by then-President Trump in June 2017. President…

On January 2, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…