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.-ChinaBIS 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 Entities2020 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 ReasonsManufacturing & 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 CompanyGuidance 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 IndustryU.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 SyriaCFIUS and President Trump Force Unwinding of 2020 Acquisition of Jupiter Systems, LLC
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, LLCSanctions 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 DisclosureHow 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