On June 21, 2024, the US Treasury Department (“Treasury”) issued a much-awaited Notice of Proposed Rulemaking (“NPRM”)āpursuant to Executive Order (“EO”) 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern”āregarding the upcoming outbound investment review regime, which prohibits or, alternatively, requires notification of certain investments into entities linked to China and engaged in subsets of three specified technologies (semiconductors and microelectronics, quantum information technologies,…
On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…
On January 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…
On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industriesāincluding transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…