Insights

The new Trump administration is focusing intensely on “cartels” and other transnational criminal organizations, particularly in the Western Hemisphere. Many of the entities designated as FTOs today are active in Latin America and the United States, and sometimes seek to extort money or have other dealings with legitimate businesses operating in their territories. The State Department’s designation of eight such entities will not only raise the pressure on the entities designated, but also will create new risks and pressures for companies operating in areas where these FTOs are active. Below, we summarize the recent developments and the ramifications of these designations for businesses.

On April 24, 2024, President Biden signed into law the National Security Supplemental fiscal package, which includes significant new sanctions and export controls authorities. Although the U.S. foreign aid commitments for Ukraine, Israel, and Taiwan headline the new law, it also (1) expands the statute of limitations for U.S. sanctions violations; (2) includes new authorities for the President to coordinate sanctions efforts with the European Union and the United Kingdom; (3) expands sanctions and export controls on Iran (including some targeted at Chinese financial institutions); and (4) includes new sanctions authorities targeting terror groups.

On April 15, 2021, the United States unveiled a sweeping series of additional sanctions on Russia, marking the first major Russia-related sanctions development of the Biden Administration and the most material such U.S. action in several years.  The actions were spearheaded by President Biden’s issuance of Executive Order 14024 (the “EO”) that grants the Department of Treasury a wide-ranging set of new designation authorities, including to designate persons “operating in” the “technology” and “defense and related material” sectors of the Russian economy.  Acting under this authority, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated six Russian entities for operating in the “technology” sector as well as expanding existing restrictions on U.S. financial institutions to now restrict participation in the primary market for certain ruble-, as well as non-ruble-denominated bonds, as well as certain ruble- or non-ruble-denominated lending activities.

Crowell & Moring attorneys will examine the myriad of challenges that companies face when balancing efforts to comply with the export regulations of both the United States and China. We will delve into both nations’ export control regulations and provide observations on areas to watch over the next year. Our areas of focus will include:

Crowell & Moring International Trade attorneys will discuss the most prominent developments of the last year and the trends we expect to continue into 2022. 

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers Jeremy Iloulian and Laurel Saito about the significant new sanctions and export control authorities included in the recently enacted National Security Supplemental fiscal package. While this legislation is best known for providing U.S. foreign aid commitments for Ukraine, Israel, and Taiwan, it also contains critical trade related provisions that (i) expand the statute of limitations for U.S. sanctions violations; (ii) give the President new authorities to coordinate sanction efforts with the US and UK; (iii) expand sanctions and export controls on Iran (with some targeting Chinese financial institutions); and (iv) provide for new sanctions authorities targeting terror groups.