Our clients across every industry are asking us what we expect to happen with the Russia sanctions under the Trump Administration. Will President Trump relax the Russia sanctions, and if so, when? All or only some of them? Or will President Trump ramp up the Russia sanctions to put pressure on Russia to agree to a peace deal with Ukraine? Will Congress get involved, and how? We will be tackling these questions and more in…
On 11 February 2025, we saw the first public multi-jurisdictional coordinated sanctions action under the Trump Administration when the United States, Australia, and the UK announced joint sanctions against alleged key members of a Russian cybercrime supply chain. This action was taken by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), Australia’s Department of Foreign Affairs and Trade, and the UK Foreign Commonwealth and Development Office (“UK FCDO”). See the US…
On December 30, 2024, the US Department of Justice (“DOJ”) issued a Final Rule intended to prevent certain countries from exploiting specific categories of sensitive personal data and government data. The Final Rule will become effective on April 8, 2025 without any further executive or regulatory action needed from the new Trump Administration. The Final Rule represents a novel approach to the national security concerns related to sensitive personal and government data that mixes elements…
On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “IFR”) revising the Export Administration Regulations (“EAR”) to impose new controls on certain biotechnology equipment and related technology. As stated in the IFR, the new controls are necessary to protect against US national security and foreign policy interests “given the dual-use nature and relevance of specific biotechnology equipment to contribute to the research and development…