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

On February 18, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed blocking sanctions pursuant to Executive Order (“E.O.”) 13850 against Rosneft Trading, S.A. (“RTSA”) and its president and board chairman, Didier Casimiro.  According to the press release announcing the designation,
Continue Reading OFAC Targets Russian Support for Maduro Regime with New Sanctions Designations

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