On July 8, the Trump administration issued an order blocking and requiring the unwinding of a 2020 acquisition by which Jupiter Systems, LLC (Jupiter), a U.S.-based audiovisual equipment supplier, was acquired by Suirui International Co., Limited (Suirui), a Chinese-based cloud communication service carrier. The administration cited national security concerns due to “the potential compromise of Jupiter’s products used in military and critical infrastructure environments.”Continue Reading CFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLC
Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
In June 2025, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced that Unicat Catalyst Technologies, LLC (Unicat), a Texas-based petrochemical company, had agreed to settle its potential civil liability relating to U.S. sanctions on Iran and Venezuela. OFAC is the primary U.S. government agency that administers and enforces U.S. sanctions.Continue Reading Sanctions Enforcement Update: DOJ Declines Prosecution After Post-Acquisition Disclosure
How International Companies Should Navigate Supply Chain Scrutiny
I recently co-authored an article with Natasha Buchler, head of ESG at Aperio Intelligence, to provide advice for companies on how to protect themselves from supply chain disruption and compliance challenges.Continue Reading How International Companies Should Navigate Supply Chain Scrutiny
U.S. Government Eases Some Restrictions on Syria
On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S. economic sanctions.Continue Reading U.S. Government Eases Some Restrictions on Syria
DOJ Settlement Highlights Customs, FCA Risks for Importers
On March 25, 2025, the U.S. Department of Justice (DOJ) announced an $8.1 million settlement in a civil case under the False Claims Act (FCA) related to alleged customs evasion by a California importer of wood flooring. The private whistleblower who reported the conduct received over $1.2 million in the matter. As we suggested in a blog post in February, these sorts of enforcement actions will proliferate under the Trump DOJ.Continue Reading DOJ Settlement Highlights Customs, FCA Risks for Importers
America First Investment Policy Sets Sights on China
On February 21, the Trump Administration released the America First Investment Policy (the memo or memorandum). The wide-ranging memo formally targets investment from the People’s Republic of China, including Hong Kong and Macau (collectively, the PRC), in sensitive U.S. sectors, modifies aspects of the Committee for Foreign Investment in the United States (CFIUS) process, and proposes new restrictions on outbound investment. Continue Reading America First Investment Policy Sets Sights on China
Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
On January 17, the Treasury Department’s Office of Foreign Assets Control (OFAC) and the Commerce Department’s Bureau of Industry and Security (BIS) announced that Haas Automation Inc. (Haas) agreed to settle potential civil liability related to multiple violations of the Ukraine-/Russia-related Sanctions Regulations and the Export Administration Regulations (EAR). Continue Reading Haas Automation Agrees to Pay More Than $2.5 Million to Settle Sanctions and EAR Violations
Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty
In the roughly four weeks since his inauguration, President Trump has announced then paused tariffs on Canada and Mexico, expanded tariffs on steel and aluminum, and suggested introducing reciprocal tariffs on the rest of the world. Continue Reading Update on Tariffs: Vigorous Enforcement Likely Amidst Uncertainty
Key Compliance Considerations for U.S. Investors Under the Treasury’s New Outbound Investment Regulations
In an article for Law360, I summarized the U.S. Department of Treasury’s new outbound investment regulations and outlined key compliance considerations for U.S. investors. I explained that the rule “aims to prevent U.S. capital and less tangible benefits like managerial services from accelerating the development of certain technologies that could harm U.S. security interests.”Continue Reading Key Compliance Considerations for U.S. Investors Under the Treasury’s New Outbound Investment Regulations
Watch Now | Managing Forced Labor and Other Supply Chain Compliance Challenges Webinar
As global supply chains continue to expand, it is essential to understand the legal, compliance, and practical challenges that arise. Forced labor, economic sanctions, corruption, and other risks can be significant, especially when relying on suppliers in China and the developing world. The early actions of the new Trump administration, and the responses from trading partners, make these challenges even more pronounced.Continue Reading Watch Now | Managing Forced Labor and Other Supply Chain Compliance Challenges Webinar