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
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John B. Reynolds
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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Davis Polk Client Memorandum: State Department Sends Hong Kong Autonomy Act Report to Congress
Posted in Economic Sanctions, OFAC
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…
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CFIUS Issues Final Rule Amending Mandatory Declaration Standards
Posted in CFIUS
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…
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Commerce Department Further Clamps Down on Huawei
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…
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President Trump Signs Hong Kong Autonomy Act, Issues Executive Order Authorizing Sanctions and Other Measures
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…
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President Trump Signs Sanctions Law to Address Human Rights Violations in China
Posted in Anti-Money Laundering, Economic Sanctions
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…
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President Trump Takes Aim at the International Criminal Court with New Sanctions Order
By John B. Reynolds & Will Schisa on
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…
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U.S. Government Tightens Export Control of Direct Products of U.S. Technologies to Huawei and Dual-Use Items to China, Russia, and Venezuela
By John B. Reynolds, Will Schisa & Joseph Kniaz on
Posted in Economic Sanctions
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…
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OFAC Makes Technical Changes to North Korea Sanctions and Civil Monetary Penalty Regulations
By John B. Reynolds, Will Schisa & Kendall Howell on
Posted in OFAC
Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced technical changes to the regulations implementing Treasury-administered economic sanctions on North Korea and new inflation-adjusted civil monetary penalties.
1. North Korea Economic Sanctions
On December 20, 2019, President Donald Trump signed into law the Otto Warmbier North Korea…
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Proposed Rule: Filing Fees for Certain CFIUS Transactions
Posted in CFIUS
The U.S. Department of the Treasury recently released a proposed rule to impose a filing fee for certain CFIUS transactions. If enacted, the proposed filing fee would raise strategic considerations for parties intending to submit a transaction for CFIUS review. Our visual memo discusses this proposal in greater detail.
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