International Trade

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Enforcement of the Uyghur Forced Labor Prevention Act Begins in the United States

The Uyghur Forced Labor Prevention Act - and its stringent import restrictions - took effect on June 21, 2022. The Act, the latest effort by the United States concerning the Uyghur population in China’s Xinjiang Uyghur Autonomous Region, greatly increases the showing that companies need to make to prove that goods produced in the XUAR, in full or in part, are entitled to entry into the United States.

Client Alert | June 23, 2022

Russia Responds to International Sanctions – An Overview of Russian Countersanctions and Further Measures against So-Called “Unfriendly States”

This client alert discusses the most significant “countersanctions” levied by Russia against “unfriendly countries” and companies that are trying to comply with the U.S., UK, EU and other sanctions regimes against Russia and Belarus.

Client Alert | May 2, 2022

Webcast: The World Reacts to the Crisis in Ukraine: Sanctions and Export Controls Imposed by the U.S., the EU, the UK, Australia, Japan and Other Countries

The United States, the European Union, the United Kingdom, Australia, Japan and other countries have issued or announced sanctions and export controls targeting Russia and the Russia-backed separatist regions of Ukraine known as the Donetsk People’s Republic and the Luhansk People’s Republic. Hear from our experts about these developments and how companies should proactively assess their exposure to the sanctions and export controls measures being discussed.

Webcasts | March 10, 2022

Webcast: The World Reacts to the Crisis in Ukraine: Sanctions Imposed by the U.S., the EU, the UK, Australia, Japan and Other Countries

The United States, the European Union, the United Kingdom, Australia, and Japan issued or announced sanctions targeting Russia and the Russia-backed separatist regions of Ukraine known as the Donetsk People’s Republic and the Luhansk People’s Republic. Hear from our experts about these developments and how companies should proactively assess their exposure to the sanctions and export controls measures being discussed.

Webcasts | March 4, 2022

Gibson Dunn Advises Shanghai Pudong Science and Technology Investment Co. in Winning CFIUS Approval

A cross-office, cross-disciplinary Gibson Dunn team represents Shanghai Pudong Science and Technology Investment Co. in matters related to its investment in ICON Aircraft, Inc.

Publications | March 4, 2022

Gibson Dunn Adds International Trade Lawyer David A. Wolber in Hong Kong

Gibson, Dunn & Crutcher LLP is pleased to announce that David A. Wolber has rejoined the firm as of counsel in the Hong Kong office.

Press Releases | March 3, 2022

United States Responds to the Crisis in Ukraine with Additional Sanctions and Export Controls

The United States has now imposed additional new sanctions and sweeping export controls that not only target key pillars of the economies of Russia and Belarus but will also have significant collateral effects across a wide range of other sectors in Russia. 

Client Alert | February 28, 2022

US and Allies Announce Sanctions on Russia and Separatist Regions of Ukraine

Our lawyers discuss sanctions issued or announced by the United States and several allies targeting Russia and the Russia-backed separatist regions of Ukraine known as the Donetsk People’s Republic and the Luhansk People’s Republic.

Client Alert | February 22, 2022

2021 Year-End Sanctions and Export Controls Update

This alert highlights trends in U.S. sanctions and export controls in 2021, including a look at the influence of the Biden Administration.

Client Alert | February 4, 2022

US Commerce Department takes more action against Chinese companies

Washington, D.C. partner Judith Alison Lee is the author of "US Commerce Department takes more action against Chinese companies" [PDF] published by Financier Worldwide in February 2022.

Article | February 1, 2022

The Uyghur Forced Labor Prevention Act Goes Into Effect in the United States

On December 23, 2022, President Biden signed the Uyghur Forced Labor Prevention Act into law. The UFLPA, which received widespread bipartisan support in Congress, is the latest in a line of U.S. efforts to address the plight of Uyghurs and other persecuted minority groups in China’s Xinjiang Uyghur Autonomous Region.

Client Alert | January 14, 2022

2021 Year-End German Law Update

Once more, 2021 demonstrated that constant change should become your friend and ally. After a second year of global uncertainty caused by the formidable challenges of the COVID-pandemic, we all long for a return “back-to-normal.” However, chances are that 2022 will continue to present drastic and unpredictable challenges.

Client Alert | January 13, 2022

SWIFT and Certain Punishment for Russia?

Washington, D.C. partner Adam M. Smith is the author of "SWIFT and Certain Punishment for Russia?" published by Foreign Affairs on January 4, 2022.

Article | January 4, 2022

Who’s Who Legal 2022 & 2021 Guides Recognize Seven Gibson Dunn Partners

Seven Gibson Dunn partners were recognized in the Who’s Who Legal 2022 Arbitration and Who’s Who Legal 2021 Trade & Customs guides.

Firm News | December 6, 2021

Seventeen Gibson Dunn Partners Recognized in Expert Guides’ Women in Business Law

Expert Guides has named 17 Gibson Dunn partners to its 2021 Guide to the World’s Leading Women in Business Law, which recognizes top female legal practitioners advising on business law.

Firm News | October 7, 2021

United States Creates New Sanctions Regime over Humanitarian Crisis in Ethiopia

On September 17, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed sanctions in response to the ongoing humanitarian and human rights crisis in Ethiopia, particularly in the Tigray region of the country.

Client Alert | September 17, 2021

UK Government Issues Further Updates on National Security Regime: A Comprehensive State of Play for Investors

This week the UK Government published still further updates on the application of the soon to come into force National Security and Investment Act 2021. We have prepared a comprehensive guide to the UK’s new national security regime, bringing together all of the developments and guidance to date. But, most importantly, we consider what investors and their advisors need to take into account now in order to mitigate risk and improve deal certainty.

Client Alert | September 8, 2021

The digitising of central bank currencies among the major economies — the current landscape

Washington, D.C. partner Judith Alison Lee is the author of "The digitising of central bank currencies among the major economies -- the current landscape," [PDF] published in the September 2021 issue of Financier Worldwide.

Article | September 1, 2021

The Humanitarian and Policy Challenges of U.S. Sanctions on the Taliban

Washington, D.C. partner Adam M. Smith is the author of "The Humanitarian and Policy Challenges of U.S. Sanctions on the Taliban," [PDF] published by Just Security on August 23, 2021.

Article | August 23, 2021

United States sanctions against Myanmar’s military conglomerates

Washington, D.C. partner Judith Alison Lee and associates Audi Syarief and Claire Yi are the authors of "United States sanctions against Myanmar's military conglomerates" [PDF] published by Financier Worldwide in June 2021.

Article | June 30, 2021

China Constricts Sharing of In-Country Corporate and Personal Data Through New Legislation

Gibson Dunn's lawyers discuss how the People’s Republic of China is clamping down on the extraction of litigation- and investigation-related corporate and personal data from China - and how this may squeeze litigants and investigation subjects in the future.

Client Alert | June 17, 2021

Biden Administration Imposes Additional Sanctions on Russia

On April 15, 2021, the United States announced a significant expansion of sanctions on Russia, including new restrictions on the ability of U.S. financial institutions to deal in Russian sovereign debt and the designation of more than 40 individuals and entities for supporting the Kremlin’s malign activities abroad.

Client Alert | April 19, 2021

US and UK Join Canada in Designating Myanmar’s Military Conglomerates, with EU Considering Further Action

On March 25, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions in response to the ongoing crisis in Myanmar (also called Burma) by designating the country’s two largest military conglomerates.

Client Alert | April 2, 2021

Cryptocurrency Developments: Office of Foreign Assets Control’s Recent Enforcement Cases Against Digital Asset Firms

On February 18, 2021, the U.S. Office of Foreign Assets Control, an agency of the Treasury Department that administers and enforces U.S. economic and trade sanctions, issued an enforcement release of a settlement agreement with BitPay, Inc. for apparent violations relating to Bitpay’s payment processing solution that allows merchants to accept digital currency as payment for goods and services. OFAC found that BitPay allowed users apparently located in sanctioned countries and areas to transact with merchants in the United States and elsewhere using the BitPay platform, even though BitPay had Internet Protocol address data for those users.  The users in sanctioned countries were not BitPay’s direct customers, but rather its customer’s customers (in this case the merchants’ customers).

Client Alert | February 24, 2021

New U.S. Sanctions and Export Controls Target Military Behind Coup in Myanmar

On February 11, 2021, in one of its inaugural foreign policy actions since taking office, the Biden Administration authorized new sanctions and export-control restrictions on Myanmar (also called Burma) in response to the Myanmar military’s recent coup against the country’s elected civilian government.

Client Alert | February 16, 2021

2020 Year-End Sanctions and Export Controls Update

Gibson Dunn provides a recap of the continuing evolution of international economic sanctions in 2020 and preparation for what may come next.

Client Alert | February 5, 2021

2020 Year-End German Law Update

At Gibson Dunn, we are proud and honored to be at your side to help solve your most complex legal questions and to continue our partnership with you in the coming year in Germany, in Europe and the world. We trust you will find this German Law Year-End Update insightful and instructive for the best possible start in 2021.

Client Alert | January 14, 2021

China’s “Blocking Statute” – New Chinese Rules to Counter the Application of Extraterritorial Foreign Laws

On January 9, 2021, the Ministry of Commerce of the People’s Republic of China issued the MOFCOM Order No. 1 of 2021 on Rules on Counteracting Unjustified Extraterritorial Application of Foreign Legislation and Other Measures. It establishes the first sanctions blocking regime in China to counteract the impact of foreign sanctions on Chinese persons.

Client Alert | January 13, 2021

The Top 10 Takeaways for Financial Institutions from the Anti-Money Laundering Act of 2020

After a complicated path to passage, on January 1, 2021 the Senate completed the override of President Trump’s veto of the National Defense Authorization Act and, as part of that legislation, passed the Anti-Money Laundering Act of 2020. The AMLA is the most comprehensive set of reforms to the anti-money laundering laws in the United States since the USA PATRIOT Act was passed in 2001. The Act’s provisions range from requiring many smaller companies to disclose beneficial ownership information to FinCEN to mandating awards to whistleblowers that report actionable information about Bank Secrecy Act/AML violations.

Client Alert | January 1, 2021

Trump Administration Sanctions Turkey’s Military Procurement Agency for 2017 Purchase of Russian Missile System

On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (SSB), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (ROE), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system.

Client Alert | December 18, 2020

The EU Adopts Magnitsky-Style Global Human Rights Sanctions Regime

On December 7, 2020, the Foreign Affairs Council of the Council of the European Union, adopted Decision (CFSP) 2020/1999 and Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses, which together establish the first global and comprehensive human rights sanctions regime to be enacted by the European Union.

Client Alert | December 10, 2020

European Commission Introduces New Complaints System to Fight Trade Barriers and Violations of Sustainable Trade and Human Rights Commitments by Third Countries

The European Commission has launched a centralized complaints system through which EU-registered companies, industry associations, trade unions and NGOs can report market access barriers or breaches by third countries of their "trade and sustainable development" commitments or commitments undertaken under the EU’s Generalised Scheme of Preferences.

Client Alert | November 30, 2020

Trump Administration Restricts Investments in Companies Linked to Chinese Military

On November 12, 2020, President Trump issued Executive Order 13959 restricting the ability of U.S. persons to invest in securities of certain “Communist Chinese military companies.”

Client Alert | November 18, 2020

The UK’s New National Security Regime

The UK Government has announced plans to upgrade and widen significantly its intervention powers on grounds of national security. Gibson Dunn lawyers detail key aspects of the proposed new regime.

Client Alert | November 18, 2020

New Controls on Emerging Technologies Released, While U.S. Commerce Department Comes Under Fire for Delay

On Monday, October 5, 2020 the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published long-awaited controls on six categories of “emerging technologies.”

Client Alert | October 27, 2020

Webcast: 2020 Sanctions and Export Controls Update

Despite the ongoing global pandemic, sanctions and export controls continue to be a most-favored enforcement tool of the U.S. government. In this webcast, join Gibson Dunn attorneys as they provide a mid-year update on the recent trends in this constantly evolving space.

Webcasts | October 15, 2020

Webcast: Chinese Companies on the Entity List: How the Trump Administration Is Weaponizing This Powerful Enforcement Tool in New Ways (A Bi-Lingual Webinar)

Under the Trump Administration, an unprecedented number of Chinese companies have been designated to the U.S. Commerce Department Entity List. In this bilingual webcast, learn about the reasons for these designations, what the effect is on these companies, their suppliers and customers, and what you can do to mitigate the disruptive effects.

Webcasts | October 14, 2020

U.S. Export Controls: The Future of Disruptive Technologies

Washington, D.C. partner Judith Alison Lee, of counsel Christopher Timura, and associates R.L. Pratt and Scott Toussaint are the authors of "U.S. Export Controls: The Future of Disruptive Technologies" [PDF] published in the NATO Legal Gazette, Issue 41 in October 2020.

Publications | October 9, 2020

Thirteen Gibson Dunn Partners Recognized in Expert Guides’ Women in Business Law

Expert Guides has named 13 Gibson Dunn partners to its 2020 Guide to the World’s Leading Women in Business Law, which recognizes top female legal practitioners advising on business law.

Firm News | September 22, 2020

China’s New Draft Export Control Law and Its Implications for International Trade

On December 28, 2019, China’s Standing Committee of the National People’s Congress (NPC) published the draft Export Control Law of the People’s Republic of China, a revised version of an earlier draft. On July 3, 2020, the NPC published a further revised draft Export Control Law of the People’s Republic of China. The resultant set of draft legislation is China’s first step towards a comprehensive and unified export control regime.

Client Alert | August 31, 2020

2020 Mid-Year Sanctions and Export Controls Update

The ongoing coronavirus has caused governments and populations to rethink how to conduct social interactions and in turn how to conduct business on a global scale. Despite the ongoing global public health crisis, the United States Government’s efforts to use its economic leverage to conduct foreign policy continues unabated. Indeed, throughout the first half of 2020, the United States continued to tighten the screws on Iran and Venezuela and has not shied away from using its economic arsenal in its escalating trade war with China.

Client Alert | August 4, 2020

Webcast: New U.S. Export Controls on Military End Use and End Users in China: How Do They Affect Chinese Companies and Their Customers/Suppliers?

In this bilingual webcast, Gibson Dunn lawyers in Washington, D.C., and Beijing discuss the April 28, 2020, action by the U.S. government imposing export controls on military end use and end users in China.

Webcasts | July 16, 2020

Human Rights Abusers (and those dealing with them) Beware: UK Introduces Its First “Magnitsky” Sanctions

On 6 July 2020, the UK Government introduced into law the “Global Human Rights Sanctions Regulations 2020,” and designated the first individuals under the Regulations in connection with their involvement in gross human rights violations.

Client Alert | July 9, 2020

European Commission Imposes Countervailing Duties on Imports from Egypt for Subsidies Provided by China

On 15 June 2020, the European Commission published Implementing Regulation 2020/776, which imposes definitive countervailing duties on imports of certain woven and/or stitched glass fibre fabrics originating in China and Egypt.

Client Alert | June 24, 2020

Trump Administration Increases Pressure on Huawei with New Export Controls That Will Limit Its Access to Semiconductors Produced with U.S. Software and Technology

On May 15, 2020, the United States Department of Commerce, Bureau of Industry and Security (BIS) announced a new rule to further restrict Huawei’s access to U.S. technology.

Client Alert | May 21, 2020

U.S. Moves to Tighten Export Controls on China and other Jurisdictions with Policies of Civil-Military Fusion

The U.S. Department of Commerce, Bureau of Industry and Security (BIS) is moving forward with long-anticipated efforts to further restrict trade in a large number of sensitive technologies.

Client Alert | May 4, 2020

Economic and Trade Sanctions Developments in Response to COVID-19

Despite pressure from U.S. and non-U.S. officials to ease sanctions on Iran in response to COVID-19, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) to date has not made substantial changes to the longstanding legal authorizations for humanitarian trade.  Nonetheless, OFAC has in recent weeks published unprecedented guidance for those who may find themselves facing challenges to comply with OFAC’s reporting requirements in light of the pandemic, acknowledging that some businesses may be forced to reallocate sanctions compliance resources to other functions.  While this is far from the substantial changes called for by some, it nonetheless indicates OFAC’s willingness to respond to the crisis with some measure of understanding for the new realities faced by many businesses affected by the pandemic.

| April 29, 2020

Final CFIUS regulations come into effect: mandatory filing requirements

Washington, D.C. partner Judith Alison Lee is the author of "Final CFIUS regulations come into effect: mandatory filing requirements," [PDF] published in the Financier Worldwide magazine's April 2020 issue.

Publications | April 21, 2020

COVID-19 & International Trade – Nation-State Responses to a Global Pandemic

Gibson Dunn lawyers provide information on the first visible impacts of the COVID-19 pandemic on and changes to export controls, tariffs, foreign direct investment regulations, and sanctions and respective enforcement. 

Client Alert | April 1, 2020

“… whatever it takes” – German Parliament Passes Far-Reaching Legal Measures in Response to the COVID-19 Pandemic

On March 25, 2020, the German Parliament (Bundestag) passed a far reaching rescue package to respond to the COVID-19 pandemic and its dramatic economic effects.

Client Alert | March 27, 2020