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Jan 17, 2025 | 
globaltradeandsanctionslaw.com | Nancy Fischer |Aaron Hutman |Steven A. Farmer |Matthew Rabinowitz
Earlier this week, the U.S. Office of Foreign Assets Control (OFAC) and the UK Office of Financial Sanctions Implementation (OFSI) published a Memorandum of Understanding (MoU), which was previously signed on October 9, 2024, formalizing a framework to govern cooperation including in relation to exchanging information, coordinating investigations, training personnel, discussing regulatory expectations and economic analyses.
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Sep 25, 2024 | 
globaltradeandsanctionslaw.com | Nancy Fischer |Aaron Hutman |Benjamin Cote |Matthew Rabinowitz
On September 23, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released for public inspection a Notice of Proposed Rulemaking that seeks to prohibit the sale or import of connected vehicles (CVs) with certain hardware and software that have a sufficient nexus to the People’s Republic of China (PRC) or Russia.
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Sep 8, 2024 | 
europeanfinancialreview.com | Matthew Rabinowitz |Steven Farmer |Matthew Oresman |Iris Karaman
By Matthew Rabinowitz, Steven Farmer, Matthew Oresman, and Iris KaramanInternational sanctions have long been a geopolitical battleground, with the US and EU historically adopting somewhat divergent approaches. The US is known for its assertive extra-territorial secondary sanctions, compelling foreign entities to comply or risk exclusion from its market. In contrast, the EU has traditionally resisted such measures, adhering to a more restrained approach.
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Jun 6, 2024 | 
globaltradeandsanctionslaw.com | Matthew Rabinowitz |Samantha Franks |Erin Kwiatkowski
On May 28, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to better implement the Biden-Harris Administration’s policy aimed at increasing support for the Cuban people. These amendments enhanced authorizations for internet-based services to promote internet freedom in Cuba, support independent Cuban private sector entrepreneurs, and expand access to financial services.
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Jun 5, 2024 | 
wsj.com | Joel Zivot |Matthew Rabinowitz
More, in fact, than before the war. If Palestinians are starving, it is Hamas’s fault, not Israel’s. The prosecutor of the International Criminal Court accuses Israel’s Prime Minister Benjamin Netanyahu and Defense Minister Yoav Gallant of violating a law against “intentionally using starvation of civilians as a method of warfare.” The statute requires a proof of intent, and the facts disprove the accusation.
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Apr 24, 2024 | 
globaltradeandsanctionslaw.com | Matthew Rabinowitz |Nancy Fischer |Aaron Hutman |Barbra Kim
On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive update to the mitigation and enforcement provisions of the CFIUS regulations since the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA). Treasury has requested public comments on the NPRM, which was published in the Federal Register on April 15, 2024.
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Apr 5, 2024 | 
globaltradeandsanctionslaw.com | Stephan Becker |Nancy Fischer |Matthew Rabinowitz |Barbra Kim
On March 29, 2024, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) issued an interim final rule (“2024 IFR”) clarifying and correcting its October 2023 interim final rules on advanced computing/supercomputers (AC/S IFR) and semiconductor manufacturing equipment (SME IFR) (collectively called the “2023 IFRs”).
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Mar 21, 2024 | 
jdsupra.com | Matthew Rabinowitz |Amaris Trozzo
TAKEAWAYS Chair of the House Select Committee on the Chinese Communist Party Mike Gallagher (R-WI-8) and Ranking Member Raja Krishnamoorthi (D-IL-8) introduced the BIOSECURE Act, with the goal of preventing foreign adversarial biotechnology companies from accessing U.S. taxpayer dollars. The Senate Homeland Security and Governmental Affairs Committee passed companion legislation for the BIOSECURE Act out of committee on March 6.
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Mar 13, 2024 | 
globaltradeandsanctionslaw.com | Nancy Fischer |Matthew Rabinowitz |Lee Petro |Barbra Kim
On March 1, 2024 the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public comment on regulations that aim to reduce the national security risks from connected vehicles (CVs) that incorporate technology from countries of concern, including the People’s Republic of China (China).
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Feb 22, 2024 | 
globaltradeandsanctionslaw.com | Nancy Fischer |Matthew Rabinowitz |Moushami P. Joshi |Samantha Franks
This past year saw a continued trend in building supply chain resiliency, as this topic has grown increasingly important following Covid-19, the conflict in Ukraine, shifting landscape on tariffs, forced labor concerns and a number of other factors. Increasingly, supply chains are having to respond to policy concerns requiring shifting production away from China, either through onshoring or friend shoring as a means of strengthening US national and economic security interests.
