The Trump Administration and Congress are tightening investment restrictions and export controls to address technology transfer concerns. These measures initially focus on China, but will have broader effects on investments in the United States and transfers of emerging technologies.
On April 6, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures designating as Specially Designated Nationals (“SDNs“) seven Russian oligarchs and 17 Russian government officials previously identified in a report issued pursuant to Section 241 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA“; see our previous blog post on this report here) under the authority of Executive Orders 13661 and 13662, pertaining to destabilizing activities by Russia in Ukraine. OFAC also designated 12 entities owned or controlled by those newly designated oligarchs and, under the separate authority of Executive Order 13582, pertaining to support for the Government of Syria, a Russian weapons-trading company and related bank. A complete list of the designated individuals and entities is available here.
On January 12, 2018, the Trump Administration released a statement that the US Government would renew waivers of certain sanctions provisions in compliance with the US Government’s commitments under the Joint Comprehensive Plan of Action (“JCPOA”). This same statement indicated, however, that future waivers would not be issued unless both the US Congress and US allies in Europe take action. This development further escalates the uncertainty about the future of the JCPOA that followed the Trump Administration’s October 2017 decision not to recertify Iran’s compliance with the requirements of the nuclear deal as described here.
On July 11, 2017, President Trump signed an Executive Order allowing additional time to consider actions by the Government of Sudan before lifting US sanctions on Sudan (“July Executive Order”).