John B. Reynolds

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Mr. Reynolds is a partner in Davis Polk’s Financial Institutions Group and the economic sanctions and national security practice. [Full Bio]

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The Anti-Money Laundering Act of 2020 implements the most extensive revisions to anti-money laundering law since the USA PATRIOT Act of 2001. The changes will affect both traditional financial institutions and FinTechs, including a new beneficial ownership provision that requires shell companies to submit ownership information to a non-public FinCEN…
Continue Reading The Anti-Money Laundering Act of 2020 – Key Takeaways

On December 28, 2020 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released Frequently Asked Questions (FAQs) relating to Executive Order 13959, “Addressing the Threat from the Securities Investments that Finance Communist Chinese Military Companies,” issued on November 12, 2020 (E.O. …
Continue Reading OFAC Belatedly Releases FAQs Regarding Ban on Investments by U.S. Persons in Companies Linked to the Chinese Military, Leaves Key Questions Unanswered

On November 12, 2020 President Trump issued a new Executive Order, “Executive Order on Addressing the Threat from the Securities Investments that Finance Communist Chinese Military Companies” (the “November 12 E.O.”) which bans, as of January 11, 2021, certain transactions by any United States person in publicly traded securities …
Continue Reading Davis Polk Client Memorandum: United States Bans Certain Investments by U.S. Persons in Companies Linked to the Chinese Military

On October 14, 2020, the U.S. State Department submitted to relevant committees of Congress the report required under Section 5(a) of the Hong Kong Autonomy Act of 2020 (“HKAA”). The announcement of the report did not involve the imposition of any new sanctions related to China or Hong Kong, as…
Continue Reading Davis Polk Client Memorandum: State Department Sends Hong Kong Autonomy Act Report to Congress

The Committee on Foreign Investment in the United States (“CFIUS”) recently promulgated final regulations that modify the scope of the mandatory declaration rules for transactions involving U.S. businesses involved in certain activities related to critical technologies (“Final Mandatory Declaration Regulations”).

As discussed in our memo available…
Continue Reading CFIUS Issues Final Rule Amending Mandatory Declaration Standards

On August 17, 2020, the Bureau of Industry and Security (BIS) at the Department of Commerce announced it was tightening restrictions on Huawei’s access to American technology through a new rule that: (1) further amends BIS’ foreign direct product (FDP) rule to restrict Huawei’s access to items produced using U.S.-origin…
Continue Reading Commerce Department Further Clamps Down on Huawei

President Trump signed into law the Hong Kong Autonomy Act and issued a new executive order, which collectively put into place a framework for the U.S. government’s policy response to China’s enactment of a new National Security Law concerning Hong Kong.  Among other things, these new authorities authorize the…
Continue Reading President Trump Signs Hong Kong Autonomy Act, Issues Executive Order Authorizing Sanctions and Other Measures

On June 17, 2020, President Trump signed into law the Uyghur Human Rights Policy Act of 2020 (the “Act”). The Act requires the President to submit to Congress within 180 days a report identifying persons responsible for human rights abuses in Xinjiang, and to impose blocking and visa sanctions against…
Continue Reading President Trump Signs Sanctions Law to Address Human Rights Violations in China

On June 11, 2020, the President issued an Executive Order (the “Order”), “Blocking Property of Certain Persons Associated with the International Criminal Court,” which authorizes the Secretary of State to impose blocking sanctions on certain persons involved in investigations by the International Criminal Court (“ICC”) of U.S. and allied military…
Continue Reading President Trump Takes Aim at the International Criminal Court with New Sanctions Order

On May 15, 2020, the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce announced an expansion of General Prohibition No. 3 of the Export Administration Regulations (EAR) to restrict Huawei’s access to semiconductor designs and chipsets that are direct products of certain…
Continue Reading U.S. Government Tightens Export Control of Direct Products of U.S. Technologies to Huawei and Dual-Use Items to China, Russia, and Venezuela