Companies May Risk Violating U.S. Sanctions Against the Taliban by Conducting Business With the Government of Afghanistan

Now that the Taliban controls Afghanistan, many businesses with economic interests or investments in the country are reevaluating potential sanctions risks. Indeed, a former OFAC official explained that, “[t]his is a new world,” and that he could not “think of any case in which a terrorist group that’s already designated became the power in charge … Read more

Designated: A Sanctions Podcast EP2: History of US Sanctions Under the JCPOA May Offer Insight to Terms of Renewed JCPOA Participation

In this episode, Jonathan Cross, Brittany Crosby-Banyai and Dan Hudson discuss the history of the Iran sanctions program under the Iranian nuclear deal, known as the Joint Comprehensive Plan of Action (“JCPOA”). They also analyze the mechanisms by which sanctions were re-imposed when the US left the agreement. These considerations offer insight as to the … Read more

United States imposes new restrictions on securities of companies allegedly linked to the Chinese military

In a significant new Executive Order (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (Order) issued on November 12, 2020, the current US Administration has prohibited “any transaction” in either the “publicly traded securities,” or “derivative[s]” of securities of companies determined to be “Communist Chinese military compan[ies]” by US authorities. Thirty-one … Read more

Trump Administration Formalizes “Team Telecom” Review of Non-US Investment in US Telecommunications Services Sector

President Trump has issued an Executive Order (“EO”) establishing the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector (the “Telecom Committee”). The Telecom Committee will advise the US Federal Communications Commission (“FCC”) concerning national security risks presented by non-US (foreign) investment in the US telecommunications services sector. Although the Telecom Committee’s … Read more