For the first time in 30 years, Congress may expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”).  In testimony before the Senate Banking Committee on January 25, 2017, three Administration officials expressed support for the Foreign Investment Risk Review Modernization Act of Read More

Following on last week’s hearing in which it heard testimony from private sector representatives, the Senate Banking Committee continued its consideration of possible reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) framework with a January 17, 2018 hearing in which … Read More

Despite his long-held stance that it is one of the worst deals ever, today President Trump again executed the necessary waivers to continue the United States’ nuclear sanctions relief to Iran in compliance with the Joint Comprehensive Plan of Action (the “JCPOA”).  The President made clear in a statement, … Read More

On October 13, 2017, President Trump announced that he would not make a quarterly certification required by the Iran Nuclear Agreement Review Act (“INARA”) because he was unable to certify that the provision of sanctions relief to Iran under the Joint Comprehensive Plan of Action (“JCPOA”) is appropriate and proportionate … Read More

On September 21, 2017, President Trump issued a new Executive Order (“E.O.”), “Imposing Additional Sanctions With Respect to North Korea.”  According to Treasury Secretary Mnuchin, the new E.O. expands the “Treasury’s authorities to target those who enable [the North Korean] regime’s economic activity.”  In particular, Secretary Mnuchin noted that … Read More

The State Department confirmed during a September 14, 2017 press briefing that the Trump administration has executed a necessary waiver to continue the United States’ nuclear sanctions relief to Iran in compliance with the Joint Comprehensive Plan of Action (the “JCPOA”).  Throughout the briefing, however, the State Department focused more … Read More

On August 24, 2017 the Trump Administration issued a new Executive Order (“E.O.”), “Imposing Additional Sanctions With Respect To The Situation In Venezuela.”  The new E.O. imposes financial sanctions on the Government of Venezuela which, according to the White House Press Release, are intended deny a critical source of … Read More

On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (the “Act”).  The measure, which was passed by substantial bipartisan majorities in the House and in the Senate, codifies certain sanctions previously imposed by Executive Order (“E.O.”), provides for new sanctions with … Read More

After several weeks of negotiations between the House and the Senate, on July 25, the House passed by an overwhelming margin (419-3, with 12 members not voting) the Countering America’s Adversaries Through Sanctions Act, which would enact new economic sanctions measures against Iran, Russia, and North Korea and curtail the … Read More

The Trump Administration submitted its second certification to Congress regarding Iranian compliance with the Joint Comprehensive Plan of Action (the “JCPOA”) on July 17, 2017.  Like the Administration’s first certification made in April 2017, it continued to focus more on Iran’s “malign activities” outside the nuclear context than on Iran’s … Read More