Shortly after taking the oath of office today, newly inaugurated President Trump signed a flurry of Executive Orders (âEOsâ) 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 US Department of Commerce (âDepartmentâ) issued a final rule (the “Rule”) on December 6, 2024 to amend provisions related to the Departmentâs review of transactions involving information and communications technology and services (âICTSâ) âdesigned, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary that may pose undue or unacceptable risk to the United States or U.S. persons.â The Rule implements important clarifications…
On October 28, 2024, the US Treasury Department (“Treasury”) issued a long-anticipated final rule (“Final Rule”)âeffective January 2, 2025âimplementing a targeted outbound investment compliance regime called for by Executive Order (“EO”) 14105 issued by President Biden on August 9, 2023. The Final Rule applies to investments by, or in some circumstances directed by, US Persons in Chinese businesses involving specified categories of technologies — namely: semiconductors and microelectronics, quantum information technologies and artificial intelligence (AI).…
On October 11, 2024, the Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order 13902 dated January 10, 2020 (“EO 13902”) designating the petroleum and petrochemical sectors of the Iranian economy as subject to US secondary sanctions. This industry sector designation adds to secondary sanctions designations announced in January 2020 under EO 13902 on the Iranian construction, mining, manufacturing, and textile sectors of the Iranian economy as well as…