The U.S. government issued guidance on October 14, 2022, emphasizing that the United States is “prepared to use its broad targeting authorities against non-U.S. persons” who continue to trade with Russia sanctions targets, particularly with private sector companies that support the Russian military.

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network issued its highly anticipated final rule implementing the beneficial ownership information reporting requirements of the Corporate Transparency Act legislation on September 29, 2022.

As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the exportation to Russia of certain categories of professional services.

Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions including economic sanctions and export controls. In addition to earlier U.S. actions, the United States has issued further trade restrictions.

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade and economic sanctions, export controls, and other financial countermeasures.

The U.S. Federal Communications Commission published a Notice of Inquiry on February 28, 2022, inviting public comment on vulnerabilities that threaten the security and integrity of the Border Gateway Protocol, which is central to the internet’s global routing system.

On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine as independent states.

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on its expectations for participants in this rapidly growing industry.

The Law of the People’s Republic of China on Countering Foreign Sanctions (Anti-Sanctions Law) was passed by the Standing Committee of the 13th National People’s Congress on June 10, 2021.

The Ministry of Commerce of the People’s Republic of China started the multi-year process of enacting a new comprehensive Export Control Law by releasing an initial draft for comment in 2017.

The Ministry of Commerce (MOFCOM) released Order No. 1 of 2021 on Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures (the Rules) effective on January 9, 2021.

Sunday, September 20, 2020, was intended to be the day on which prohibitions would go into effect on ByteDance Ltd. (ByteDance) and Tencent Holdings Ltd. (Tencent) and their subsidiaries—makers of the TikTok and WeChat apps, respectively.

President Donald Trump signed two executive orders (the EOs) on August 6, 2020, an Executive Order on Addressing the Threat Posed by TikTok (TikTok EO) and an Executive Order on Addressing the Threat Posed by WeChat (WeChat EO).

The U.S. government on July 14, 2020, took two significant steps to address the evolving situation in Hong Kong.

International trade and cyber security issues, compounded by the coronavirus pandemic, have increased existing tensions and distrust between the United States and China.

The U.S. Department of Commerce, Bureau of Industry and Security (BIS) on April 28, 2020, published two final rules and a proposed rule that substantially tighten the controls in the Export Administration Regulations (EAR).

What is a thing? On February 10, 2020, the U.S. Court of Appeals for the Federal Circuit gave us a new answer to this old philosophical question.

The Committee on Foreign Investment in the United States (CFIUS) published two final rules on January 17, 2019, to implement the Foreign Investment Risk Review Modernization Act (FIRRMA) enacted in August 2018.

A recent International Trade Commission administrative law judge ruling offers important lessons to anyone involved in the battles over U.S. intellectual property rights, Perkins Coie IP attorneys say. The ALJ sanctioned the complainant’s attorneys twice—for producing 160,000 pages of documents late, and for dropping four claims the day before an evidentiary hearing. And they almost got sanctioned a third time.

U.S. Citizenship and Immigration Services (USCIS) announced on December 6, 2019, that it has completed testing and will implement a new online registration process for the upcoming H-1B cap-subject visa season that begins on March 1, 2020.

China is in the process of drafting a new comprehensive Export Control Law, following on the June 2017 release of an initial draft for comment (Draft Export Control Law) by the Ministry of Commerce of the People’s Republic of China (MOFCOM).

The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities in accordance with national security and foreign policy.

The U.K. Modern Slavery Act of 2015, which was modeled after the California Transparency in Supply Chains Act, requires companies falling under its jurisdictional hook (and there are many) to honestly and completely disclose their efforts to eradicate trafficked, slave, indentured, coerced and child (collectively “forced”) labor from their supply chains.

On October 10, 2018, CFIUS issued interim pilot program regulations to review foreign investments in critical technologies to consider whether foreign investment might be eroding U.S. technological superiority.

Driven by a newly aggressive “America First” trade policy under the Trump administration, global trade barriers are increasing rapidly, with proposals for new tariffs and non-tariff barriers issued by U.S. and foreign governments on a near-daily basis.

The United States will reimpose sanctions against Iran to implement President Donald Trump’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), a multilateral agreement under which Iran agreed to curb development of certain nuclear capabilities in exchange for the United States lifting specified sanctions.

President Donald Trump’s recent decision to impose a wide range of restrictive new measures against China, in response to China’s practices involving U.S. intellectual property and technology, creates new risks, barriers—and in certain cases, opportunities—for U.S. industries that depend on China as an important market, production center and trading partner.

An importer of natural gas from Canada filed suit on February 23, 2018, alleging that U.S. Customs and Border Protection unlawfully denied preferential treatment for its imports under NAFTA.

Significant antidumping and countervailing duties (AD/CVDs) on imports of softwood lumber from Canada will continue following the U.S. International Trade Commission final affirmative injury determination made yesterday.

Retailers are looking ahead to the holiday season, but many are also watching the NAFTA renegotiation, which is ambitiously (and improbably) slated to conclude around the holiday season.

A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran?

On May 18, 2017, United States Trade Representative Robert Lighthizer notified Congress that he is seeking to renegotiate the North American Free Trade Agreement (NAFTA). 

The Foreign Agents Registration Unit of the U.S. Department of Justice has updated its website to make available to the public searchable and downloadable informational materials filed by foreign agents. Informational materials are documents or other communications distributed on behalf of a foreign principal to two or more people.

President Trump has now appointed the senior members of his administration (some of whom remain subject to U.S. Senate confirmation) who will help him develop, coordinate and enforce U.S. trade policy.

On the campaign trail, President-elect Trump adopted a contentious approach towards foreign trade, focusing on Chinese “theft of American trade secrets” and suggesting, at times, potential isolationism for U.S. businesses.

Following a recent breakdown of bilateral negotiations, a group of U.S. companies calling itself COALITION (Committee Overseeing Action for Lumber International Trade or Negotiations) filed antidumping and countervailing duty petitions with the U.S. Department of Commerce and the ITC.

President-elect Donald Trump has promised action that could drastically change the rules for U.S. importers and exporters, foreign shippers to the United States and service providers.

U.S. Customs and Border Protection (CBP) has issued new interim regulations to remedy and penalize evasion of antidumping and countervailing duties (AD/CVD) orders.

The federal government took another step in the fight against human trafficking and forced labor.  President Obama signed into law on February 24, 2016, the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA).

This week Congress amended U.S. customs law to create new risks and opportunities for companies importing goods into the United States.

The United States suspended certain “secondary sanctions” against Iran that apply to non-U.S. companies for transactions that take place outside of the United States and do not involve U.S. persons on “Implementation Day,” January 16, 2016, under the Joint Comprehensive Plan of Action (JCPOA).

One month after announcing the conclusion of negotiations, the Office of the United States Trade Representative (USTR) today released the full text of the Trans-Pacific Partnership agreement (TPP).

This week, the 12 Trans-Pacific Partnership (TPP) member countries decided the final terms of what they report is a far-reaching agreement (Agreement or TPP Agreement).

Iran has reached an agreement with the international community that would require Iran to restrict aspects of its nuclear program in return for the eventual lifting of certain U.S. and international sanctions against it. The agreement is called the Joint Comprehensive Plan of Action (JCPOA).

President Obama signed Trade Promotion Authority (TPA) into law this week. TPA permits the Obama administration to submit free trade agreements (FTAs) to Congress for a simple yes-or-no vote, without amendment.

When the White House recently announced that it was extending sanctions against Russia for another year, it cited a continued “unusual and extraordinary threat” from Russia’s activities in Ukraine.  President Obama also signed the Ukraine Freedom Support Act of 2014 at the end of last year, which authorized the White House to enact further sanctions on Russia.

During the same week that President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba, the president signed congressional legislation authorizing additional sanctions against Russia (December 19, 2014) and Venezuela (December 18, 2014). 

On December 17, 2014, President Barack Obama announced sweeping changes in the diplomatic and trade relationships between the United States and Cuba.  These changes, outlined below, will require time to implement; certain aspects will require Congressional approval. 

On November 10, United States Trade Representative Michael Froman announced a major breakthrough in negotiations with China to eliminate tariffs on information technology products by expanding the scope of the International Technology Agreement (ITA).

U.S. government agencies announced this week that they have suspended issuing export licenses to companies sending or releasing sensitive goods, services and technology to Russia.

Events are rapidly evolving with respect to Russia’s recent military incursion into, and subsequent annexation of, Ukraine’s Crimean Peninsula. The Obama Administration considers Russia’s acts to be clear violations of international law and believes Russia should incur significant costs for threatening the peace, stability and security of Ukraine and the region. To that end, the United States and other nations have implemented sanctions against Russia.

On December 31, 2013, SolarWorld Industries America (SolarWorld), a U.S. manufacturer of solar panels, petitioned the Department of Commerce (Commerce) and the International Trade Commission (ITC) for additional tariffs on imports of solar products from China and Taiwan that SolarWorld alleges are dumped (sold at less than fair value) and/or on Chinese products that benefit from Chinese government subsidies.

The United States agreed to suspend certain sanctions against Iran over the weekend as part of an agreement to curb the Iranian nuclear program.  The agreement, which provides for a six-month first step towards a comprehensive solution for Iran’s nuclear program and related sanctions, is between Iran and the United States, the United Kingdom, Germany, France, Russia, and China, collectively referred to as “P5+1.”

The U.S. Bureau of Industry and Security (BIS) has issued a request for public comments on the effect of extending foreign-policy based export controls for another year. Such controls require annual extension, including a review by BIS, a request for public comments, and a related report to Congress.

The U.S. Bureau of Industry and Security has published its Final Rule on the much anticipated license exception Strategic Trade Authorization 76 Federal Register 35276. This new license exception is the next significant step in the Obama Administration's Export Reform Initiative, intended to facilitate exports between the United States and its close partners and allies by easing the license burden on exports of numerous items.

The U.S. Treasury Department, chair of the Committee on Foreign Investment in the United States ("CFIUS"), recently published guidance on the types of transactions previously reviewed by CFIUS that have presented national security considerations ("Guidance").  The Guidance is intended to provide insight into how CFIUS identifies the national security effects of covered transactions and may assist parties considering whether to file a voluntary notice of a transaction with CFIUS [1]. This is an important determination because, although filing a CFIUS notice is voluntary, the parties may be forced to unwind a transaction where no filing was made if the President later determines it poses national security risks.