On July 1, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published the International Criminal Court-Related Sanctions Regulations to implement Executive Order (“EO”) 14203, “Imposing Sanctions on the International Criminal Court”, issued on February 6, 2025. EO 14023 authorized sanctions on foreign persons engaged in certain efforts by the International Criminal Court (“ICC”) to target the United States and Israel. EO 14023 In EO 14203, President Trump finds that the ICC…
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 US Department of Commerce (“Department”) issued a final rule (the “Rule”) on December 6, 2024 to amend provisions related to the Department’s review of transactions involving information and communications technology and services (“ICTS”) “designed, 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.” The Rule implements important clarifications…
On October 28, 2024, the US Treasury Department (“Treasury”) issued a long-anticipated final rule (“Final Rule”)—effective January 2, 2025—implementing 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).…