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As US toughens CFIUS oversight of foreign investments in sensitive sectors of the economy, we assess the key factors in play President Biden recently issued an Executive Order on Ensuring Robust Consideration of Evolving National Security Risks by the Committee on Foreign Investment in the United States (the Foreign Investment EO). It directs increased scrutiny by the Committee … Read more
Our previous blog post discussed the G-7’s recent proposal to impose a price cap on Russian oil in an effort to diminish the energy revenues of the Russian state. In this post, we examine the new guidance issued by the U.S. Department of the Treasury (“Treasury”), Office of Foreign Assets Control (“OFAC”) establishing a framework … Read more
In this mini-series, we discuss the recent sanctions measures implemented in the U.S., E.U., and U.K. as a response to the crisis in Ukraine. In this episode, Jonathan Cross, Susannah Cogman, and Brittany Crosby-Banyai focus on the recent sanctions measures that impact Russian investments. Read more
On July 27, 2022, the US Senate unanimously passed a nonbinding, bipartisan resolution to designate the Russian Federation as a “State Sponsor of Terrorism” (SST). In parallel, a bipartisan group of members of the US House of Representatives introduced a bill on July 28, 2022 to designate Russia as an SST. See H.R.8568. These actions … Read more
The U.S. government has continued to impose additional Russia-related sanctions measures in response to Russia’s invasion of Ukraine. We previously discussed Russia-related sanctions and export control measures imposed by the U.S. on July 7, July 6, June 13, and in earlier posts. In the U.S. Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) … Read more
This post provides an update regarding further Russia-related sanctions measures in the United States. New General Licenses On June 28, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued several new General Licenses (“GLs”): GL 39 authorizes certain transactions ordinarily incident and necessary to the wind down of any transaction … Read more
On June 21, 2022, U.S. Customs and Border Protection (“CBP”) began enforcing the Uyghur Forced Labor Prevention Act (Pub. L. 117-78) (the “UFLPA”), which establishes a “rebuttable presumption” that goods produced wholly or in part in the Xinjiang Uyghur Autonomous Region (“XUAR”) in China or by certain identified entities are made with forced labor, and … Read more
On June 6, 2022, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued seven new FAQs (the “New FAQs”) that, among other things, substantially revise OFAC’s prior definition of “new investment” under Executive Orders (“E.O.s”) 14066, 14068, and 14071 (collectively, the “Investment E.O.s”) under the U.S. Russia sanctions program, … Read more
On June 1, 2022, the Office of Foreign Assets Control of the US Department of the Treasury (“OFAC”) issued three new FAQs regarding OFAC’s Chinese Military-Industrial Complex Companies (“CMICs”) Sanctions program. The new FAQs were issued to coincide with the deadline by which US persons were authorized to divest from the securities of designated CMIC … Read more
