On January 7, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an Order resolving allegations that Exyte Management GmbH (Exyte), a Germany-based company, committed 13 violations of the Export Administration Regulations (EAR) in China. The violations were committed by Exyte’s Chinese affiliate, Exyte Shanghai Ltd (Exyte China).Continue Reading Export Enforcement Update: EAR99 “In-Country” Transfers Lead to Penalty
Update on Venezuela: Significant Trade Restrictions and Risks Continue
We hope everyone had a great holiday. 2026 is now officially off and running, and particularly in light of recent events, we want to briefly summarize current trade restrictions related to Venezuela. The landscape will almost certainly shift soon – and often – and we will provide updates as often as possible. Importantly, at present, there continue to be significant restrictions when doing business in and with Venezuela.Continue Reading Update on Venezuela: Significant Trade Restrictions and Risks Continue
OFAC Enforcement Update: Recent Penalties Highlight Expectations Around Beneficial Ownership, Transparency, and Reporting Obligations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently announced two separate enforcement actions against IPI Partners, LLC and Gracetown, Inc. for violations of Ukraine-/Russia-related sanctions. OFAC is the agency responsible for administering and enforcing U.S. economic sanctions programs.
These actions highlight OFAC’s willingness to scrutinize private equity and other investment
UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China
On October 30, U.S. Treasury Secretary Scott Bessent announced that the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will delay the implementation of the recently announced BIS Affiliates Rule for one year. Continue Reading UPDATE: BIS Affiliates Rule Suspended for One Year Following U.S.-China
BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities
Please note that the content below was posted on October 2, 2025. We have since provided updated guidance on the topics discussed in this post here.
On September 29, the U.S. Department of Commerce Bureau of Industry and Security (BIS) issued a new interim final rule that significantly expands the scope of U.S. export controls. Entitled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities and referred to by BIS as the “Affiliates Rule,” the rule is designed to close a longstanding loophole by extending restrictions to foreign affiliates of parties already subject to export restrictions, including those parties designated on the Entity List and the Military End-User (MEU) List.Continue Reading BIS Closes Loophole: New Rule Expands Export Controls to Affiliates of Listed Entities
2020 Deal Dismantled for National Security Reasons
We recently authored an article for Law360 detailing a July 8 order by the Trump administration to block and force the unwinding of a transaction that occurred more than five years ago.Continue Reading 2020 Deal Dismantled for National Security Reasons
Manufacturing & Industrial: Outlook & Trends
Manufacturers are operating in a period of both opportunity and uncertainty. Buyer demand remains strong in a competitive M&A market, but shifting tariff policies, heightened immigration enforcement, and an evolving regulatory agenda are reshaping how companies plan for growth.
Continue Reading Manufacturing & Industrial: Outlook & Trends
Huge Export Penalty for U.S. Technology Company
On July 28, various arms of the U.S. government announced concurrent export enforcement resolutions involving Cadence Design Systems, Inc. (Cadence), a California-based software and technology firm. Cadence will pay over $140 million in combined net criminal and civil penalties and forfeiture.Continue Reading Huge Export Penalty for U.S. Technology Company
Guidance on Compliance Challenges in Oil and Gas Industry
I recently authored an article for World Pipelines providing guidance on compliance challenges in the oil and gas industry.Continue Reading Guidance on Compliance Challenges in Oil and Gas Industry
U.S. Government Ends Sanctions on Syria
On June 30, President Trump signed Executive Order 14312, “Providing for the Revocation of Syria Sanctions” (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has also lifted nearly all sanctions on Syria.Continue Reading U.S. Government Ends Sanctions on Syria