On July 28, 2025, Cadence Design Systems Inc., a global electronic design automation technology company based in San Jose, California, agreed to plead guilty to export violations in a settlement with the U.S. Department of Justice’s National Security Division and the U.S. Attorney’s Office for the Northern District of California, and resolved a civil enforcement
Focus on Transnational Cartels Continues: FinCEN Targets Three Mexican Financial Institutions with Special Measures, Restricting Their Access to U.S. Financial System
Reflecting the administration’s continued focus on transnational cartels, on June 25, 2025, FinCEN identified three Mexican financial institutions as “primary money laundering concerns,” and imposed restrictions on U.S. financial institutions from engaging in transactions with these entities.
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Client Alert: New BIS Guidance Continues Trend of Enhanced EAR Compliance Expectations for Financial Institutions
In new guidance published on October 9, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued recommendations about its expectations for financial institutions in complying with U.S. export control obligations.
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Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.
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Commerce, Treasury, DOJ Publish Tri-Seal Sanctions and Export Control Compliance Note
On March 6, 2024, the Department of Commerce, the Department of the Treasury, and the Department of Justice published a Tri-Seal Compliance Note titled “Obligations of foreign-based persons to comply with U.S. sanctions and export control laws” (the “Note”). The Note stresses that U.S. persons are not the only entities subject to U.S. sanctions and
BIS Publishes FAQs on Export Controls of Semiconductors and Advanced Computing Items
On December 29, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) published a series of Frequently Asked Questions (FAQs) addressing comments received on the October 13, 2022 interim final rules that amended, and in some cases expanded, U.S. export restrictions on semiconductor manufacturing items and advanced computing items and end uses.
FinCEN Proposes Delaying Some Beneficial Ownership Filing Deadlines and Releases Additional Guidance for Beneficial Ownership Information Reporting
In advance of the impending January 1, 2024 effective date for the U.S. Treasury Department, Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership information (“BOI”) reporting requirements, FinCEN has proposed an extension of the reporting deadline for some reporting companies, and issued additional guidance regarding BOI reporting requirements, including a Small Entity Compliance Guide, a
Executive Order and Rulemaking on U.S. Outbound Investment
- Key takeaway #1 Issuance of Executive Order and Rulemaking: On August 9, 2023, President Biden issued a long-anticipated “Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” (the “Executive Order”). The Executive Order, which the President issued pursuant to the
State Department Publishes Fact Sheet on AUKUS Trade Authorization Mechanism
On July 10, 2023, the State Department released a Fact Sheet with additional details on the AUKUS Trade Authorization Mechanism (ATAM). ATAM appears likely to operate as a license exemption under the International Traffic in Arms Regulations (ITAR), leveraging the existing ITAR §126.4, to authorize transfers of certain approved categories of defense articles and
China’s Revised Counterespionage Law and Recent Actions Highlight Challenges for U.S. Companies Operating in China
While the Biden’s administration’s recent corporate enforcement actions and initiatives have garnered significant press attention, China has engaged in recent months in a series of less-publicized corporate enforcement actions and initiatives against non-Chinese companies (mostly, but not exclusively, U.S.-based) operating in the country, including through new investigations, raids of China-based offices, and even detention of