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Biden Administration to Implement New National Security Rules Targeting Personal Data
On February 28, 2024, the Biden administration announced the creation of a new national security regulatory regime that will prohibit or restrict certain transactions involving bulk sensitive US personal data or government-related data and specified “countries of concern.” The Biden administration announced the regime in a new executive order, Preventing Access to Americans’ Bulk…
In First of Its Kind Action, Commerce Moves to Regulate Foreign Tech in Vehicles
In a first of its kind action, the US Department of Commerce has begun a rulemaking process to prohibit or impose conditions on certain transactions involving foreign technology used in so-called “connected vehicles” or “CVs,” as defined below for automotive applications.
The measure, announced by Commerce on February 29, 2024 in a press release and…
OFSI Publishes Expanded Guidance on Financial Sanctions Licensing Process and Principles
On February 27, 2024, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) published a number of guidance documents on financial sanctions licensing addressing the process of applying for a licence, as well as the principles applied when making licensing decisions relating to designated individuals. Publication of the guidance follows a recent court case…
US Government Imposes New Russia Sanctions, Designating Over 500 Parties and Issuing Interagency Russia Business Advisory
On February 23, 2024, the United States issued a broad set of new Russia-related sanctions and export controls in response to the second anniversary of Russia’s invasion of Ukraine and the February 16, 2024, death of opposition leader, Aleksey Navalny, in Russian custody.
The Treasury Department’s Office of Foreign Assets Control (OFAC), the Commerce Department’s…
OFAC Issues Significantly Revised NGO Authorizations for North Korea
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has published major revisions to its humanitarian authorizations and other general licenses under the North Korean Sanctions Regulations (“NKSR”), which took effect on February 16, 2024. These regulatory changes expand the scope of authorized activity in North Korea, which should lead to fewer…
OFSI Publishes Update on New Russia Sanctions Reporting Requirements
The UK government introduced new reporting requirements under The Russia (Sanctions) (EU Exit) Regulations 2019 (“Russia Regulations”) in December 2023, with the goal of strengthening transparency in relation to assets frozen under the regime and assisting HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) to monitor compliance with, and detect evasion of, financial sanctions administered…
UK NECC Publishes Amber Alert on Sanctions Evasion in the Art Storage Sector
The UK’s National Economic Crime Centre (“NECC”) recently issued an amber alert concerning the sanctions evasion, money laundering, and trafficking in cultural property risks presented to UK industries linked to artwork storage facilities and the art storage sector (the “Amber Alert”). The Amber Alert highlights that criminals are finding ways to utilize the art market…
Potential new SAR-like Reporting Requirements for Certain U.S. Real Estate Transactions
On February 8, 2024, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (2024 NPRM) about Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regulations concerning persons involved in residential real estate closings and settlements. To promote U.S. AML/CFT objectives, the NPRM proposes a…
Commerce Proposes Significant New Regulations on AI Training and IaaS Providers
In a recent proposed rule, the Department of Commerce has taken additional steps toward imposing significant regulations on infrastructure as a service (IaaS) providers, including providers engaged in training certain large AI models. The notice of proposed rulemaking (NPRM) is published by Commerce’s Bureau of Industry and Security (BIS) and, in particular, its…