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…
Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (“EOs”) and other executive actions. This include several actions related to US sanctions and export controls. Authority to Designate Cartels as Foreign Terrorist Organizations or Specially Designated Global Terrorists Trump signed an EO Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists. This EO creates a legal authority to designate certain international…
The Biden Administration issued another round of sanctions against Russia in its final days, with less than a week left in the Administration. This followed on the heels of major sanctions imposed by OFAC on Russia’s energy sector just five days prior – see our blog post on that development here. Specifically, on January 15, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Department of State (“State”)…