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

On January 13, 2020, the U.S. Treasury Department promulgated its final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) to reform the authority and jurisdiction of the Committee on Foreign Investment in the United States (CFIUS). The final regulations were released in two parts: one addressing
Continue Reading CFIUS Issues Final FIRRMA Regulations

On January 10, 2020, President Trump issued Executive order 13902 (“E.O. 13902”) which authorizes the U.S. Department of the Treasury to impose additional sanctions targeting the construction, mining, manufacturing and textiles sectors of the Iranian economy, as well as any other sector of the Iranian economy subsequently specified by the
Continue Reading “Maximum Pressure” to the Max: United States Sanctions Additional Sectors of Iran’s Economy

On November 27, 2019, the United States Department of Commerce issued an advance notice of proposed rulemaking seeking public comment on “regulations that would govern the process and procedures that the Secretary of Commerce will use to identify, assess, and address certain information and communications technology and services transactions that
Continue Reading U.S. Department of Commerce Proposes Rule Governing Information and Communications Technology and Services

On October 23, 2019, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) acting at the direction of President Trump and in consultation with the State Department, lifted sanctions on three Turkish government ministers and two Turkish government ministries and removed them from the List of Specially Designated
Continue Reading OFAC Lifts Short-Lived Turkey Sanctions

On October 14, 2019, President Trump issued an Executive order authorizing sanctions targeting the Turkish government in connection with its military operations in northern Syria. The U.S. government also announced a 50% tariff on imports of steel from Turkey and cancellation of trade agreement negotiations.

The initial sanctions announced by
Continue Reading Davis Polk Client Memorandum: United States Sanctions Turkish Government over Syrian Incursion

In response to what Treasury Secretary Steven Mnuchin called “Iran’s brazen attack against Saudi Arabia,” and following President Trump’s tweet ordering Treasury to “substantially increase Sanctions on the country of Iran,” today the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions on the Central Bank of Iran
Continue Reading U.S. Imposes Additional Sanctions on Central Bank of Iran

In the latest development in the complex and evolving sanctions targeting the Government of Venezuela, on September 9, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 34,  The new GL authorizes transactions involving certain individuals that would otherwise be prohibited
Continue Reading New General License Reinforces Broad Scope of Sanctions Against the Government of Venezuela

The Department of Commerce added 46 more non-U.S. affiliates of Huawei Technologies Co., Ltd. to the Bureau of Industry and Security (BIS) Entity List, joining Huawei and 68 of its non-U.S. subsidiaries that were put on the list in May.  The Commerce Department also extended a temporary general license permitting
Continue Reading Davis Polk Client Memorandum: Commerce Department Extends Huawei General License, Adds More Huawei Affiliates to Entity List

Late on the evening of August 5, 2019, President Trump issued a new Executive order imposing blocking sanctions on the Government of Venezuela (“GoV”).  The order builds on prior limited sanctions imposed on the GoV, as well as blocking sanctions imposed on certain GoV agencies and state-owned companies
Continue Reading Davis Polk Client Memorandum: United States Imposes Blocking Sanctions on the Government of Venezuela

On August 3, 2019, the U.S. Department of State and the Department of the Treasury announced a second round of sanctions on the Russian Federation pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s involvement in a
Continue Reading Davis Polk Client Memorandum: Second Round of Sanctions on the Russian Federation under Chemical and Biological Weapons Control and Warfare Elimination Act