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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

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

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

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

Coronavirus: EU Economic and Fiscal Measures

Governments of many EU Member States – as well as the European Commission - have announced special measures to support businesses affected by the COVID-19 pandemic.  Gibson Dunn identifies some of the key fiscal measures being put in place by the governments of the UK, France and Germany to help companies manage their cash flows during these times.

Client Alert | March 27, 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

Senate Advances the CARES Act, the Largest Stimulus Package in History, to Stabilize the Economic Sector During the Coronavirus Pandemic

Gibson Dunn provides a comprehensive look at the CARES Act passed by the Senate on March 25, 2020, the largest emergency stimulus package in United States history.

Client Alert | March 26, 2020

Gibson Dunn Earns 155 Rankings from Chambers Global 2020

In the 2020 edition of Chambers Global, Gibson Dunn earned 155 total rankings – 56 firm practice group rankings and 99 individual rankings. The firm and its lawyers were recognized globally and in the Asia-Pacific, Europe, Latin America and Middle East regions, with additional recognitions in Belgium, China, France, Germany, India, Indonesia, the Philippines, Singapore, the United Arab Emirates, the United Kingdom and the United States.

Firm News | March 5, 2020

CFIUS Reform: Top Ten Takeaways from the Final FIRRMA Rules

On February 13, 2020, final regulations went into effect to expand the scope of inbound foreign investment subject to review by the Committee on Foreign Investment in the United States (CFIUS).

Client Alert | February 19, 2020

Who’s Who Legal Names 12 Partners to Practice Guides for Trade & Customs, Arbitration and Restructuring & Insolvency

Who’s Who Legal guides for 2019 and 2020 named 12 Gibson Dunn partners to practice guides in their respective fields. Washington, D.C. partners Donald Harrison, Judith Lee and Adam Smith were recommended for Trade & Customs.

Firm News | January 30, 2020

2019 Year-End Sanctions Update

Gibson Dunn provides a recap of the continuing evolution of international economic sanctions in 2019 and preparation for what may come next.

Client Alert | January 23, 2020

2019 Year-End German Law Update

Gibson Dunn lawyers in Frankfurt and Munich provide a recap of developments in German law across numerous areas during 2019.

Client Alert | January 10, 2020

Developments in the Defense of Financial Institutions – The International Reach of the U.S. Money Laundering Statutes

As part of a series of regular analyses of the unique impact of white collar issues on financial institutions, Gibson Dunn lawyers examine how DOJ has stretched U.S. money laundering statutes—perhaps to a breaking point—to reach conduct that occurred outside of the United States.

Client Alert | January 9, 2020

DOJ National Security Division Releases Updated Guidance on Voluntary Self-Disclosures

On December 13, 2019, the U.S. Department of Justice announced changes to its policy governing the treatment of voluntary self-disclosures (or “VSDs”) in criminal sanctions and export control investigations.

Client Alert | December 13, 2019

New Guidance on Internal Compliance Programs (“ICPs”) – What Regulators on Both Sides of the Atlantic Expect from International Business

The European Union has become more active in addressing EU common foreign and security policy (“CFSP”) objectives with the help of what it calls “restrictive measures,” i.e., EU Financial and Economic sanctions.

Client Alert | December 5, 2019

U.S. Congress Passes The Hong Kong Human Rights and Democracy Act of 2019; Awaiting Presidential Signature

On November 21, 2019, amid mounting tensions between China and Hong Kong, the U.S. Congress passed the Hong Kong Human Rights and Democracy Act of 2019 and sent it to the President for his signature. 

Client Alert | November 26, 2019

U.S., EU, and UN Sanctions: Navigating the Divide for International Business

Washington, D.C. partner Adam Smith and of counsel Stephanie Connor and Munich associate Richard Roeder are the authors of U.S., EU, and UN Sanctions: Navigating the Divide for International Business, published by Bloomberg Law in 2019.

Publications | November 15, 2019

Adam Smith Named Among Global Investigation Review’s 25 Most Respected Sanctions Lawyers in Washington, D.C.

Global Investigations Review named Washington, D.C. partner Adam Smith among its 25 Most Respected Sanctions Lawyers in Washington, D.C., which features individuals who are most trusted with sanctions cases and “are working on the most significant cases.” The list was published November 1, 2019.

Firm News | November 4, 2019

New U.S. Sanctions Targeting Turkish Government in Response to Military Operations in Syria

On October 14, 2019, the Trump administration authorized new sanctions against the Government of Turkey in response to that country’s recent military incursion into northern Syria, an action the U.S. government condemned as “endangering innocent civilians, and destabilizing the region, including undermining the campaign to defeat ISIS.”

Client Alert | October 18, 2019

Trump administration using a variety of measures to target Chinese tech companies

Washington, D.C. partner Judith Alison Lee and associate R.L. Pratt are the authors of "Trump Administration Using a Variety of Measures to Target Chinese Tech Companies," [PDF] published in Financier Worldwide in October 2019.

Publications | October 9, 2019

Proposed CFIUS Regulations: The U.S. Remains Open for Business … but Read the Fine Print

On September 17, 2019, the U.S. Department of the Treasury issued proposed regulations to implement the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which expanded the scope of inbound foreign investment subject to review by the Committee on Foreign Investment in the United States (CFIUS).

Client Alert | September 20, 2019

Gibson Dunn Lawyers Recognized in the Best Lawyers in America® 2020

The Best Lawyers in America® 2020 has recognized 158 Gibson Dunn attorneys in 54 practice areas. Additionally, 48 lawyers were recognized in Best Lawyers International in Belgium, Brazil, France, Germany, Singapore, United Arab Emirates and United Kingdom.

Firm News | August 15, 2019

New U.S. Sanctions Targeting Venezuelan Government

On August 5, 2019, the Trump administration imposed new sanctions on the Government of Venezuela by freezing the property and assets of the regime of Venezuelan President Nicolás Maduro as well as those who provide it with “material support.”

Client Alert | August 7, 2019

The EU Introduces a New Sanctions Framework in Response to Cyber-Attack Threats

On May 17, 2019, the EU established a sanctions framework for targeted restrictive measures to deter and respond to cyber-attacks that constitute an external threat to the EU or its Member States

Client Alert | June 19, 2019

Citing a National Emergency, the Trump Administration Moves to Secure U.S. Information and Communications Technology and Service Infrastructure

On Wednesday, May 15, 2019, the Trump Administration took two separate, but related moves toward securing the information and communications technology and services (ICT) infrastructure of the United States.

Client Alert | May 20, 2019

In the Wake of International Protectionism, France Strengthens Its Enforcement Scheme Applicable to Foreign Investments

On May 16, 2019, the French Constitutional Court (Conseil constitutionnel) cleared most of the provisions of the ambitious so-called “Pacte” Statute on the development and transformation of businesses.

| May 17, 2019

Iran Steps Back from Nuclear Deal as Trump Administration Increases Sanctions Pressure

May 8, 2019, was the one-year anniversary of the U.S. decision to withdraw from the 2015 Iran nuclear deal, formally known as the Joint Comprehensive Plan of Action (“JCPOA”), and it was eventful.

Client Alert | May 10, 2019

OFAC Releases Detailed Guidance on Sanctions Compliance Best Practices

On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released extensive new guidance regarding what constitutes an effective sanctions compliance program. The document is significant in that it represents the most detailed statement to date of OFAC’s views on the best practices that companies should follow to ensure compliance with U.S. sanctions laws and regulations.

Client Alert | May 6, 2019

President Trump Ramps Up Cuba Sanctions Changes — Allows Litigation Against Non-U.S. Companies Conducting Business in Cuba

Frustrated by Cuba’s continued support of the Maduro regime in Venezuela, the Trump administration announced on April 17, 2019 that it will permit U.S. individuals and companies to initiate litigation against foreign individuals and companies that have past or present business in Cuba involving property that the Cuban government confiscated in 1959.

Client Alert | May 1, 2019

CFIUS Developments: Notable Cases and Key Trends

The Committee on Foreign Investment in the United States (CFIUS) kicked into high gear in spring 2019 with a number of notable cases and developments.

Client Alert | April 24, 2019

EU Regulation on Establishing a Framework for Screening of Foreign Direct Investments into the European Union Has Been Adopted

The regulation of the European Parliament and of the Council establishing a framework for screening of foreign direct investments (“FDI”) into the European Union (“EU”) was adopted on March 5, 2019.

Client Alert | March 5, 2019

2018 Year-End Sanctions Update

2018 was another extraordinary year in sanctions development and enforcement. Gibson Dunn provides a recap of the continuing evolution of sanctions in 2018 and preparation for what may come next.

Client Alert | February 11, 2019

Venezuela Update: The Trump Administration Imposes Oil Sanctions to Effect Regime Change

On January 28, 2019, amid mounting tensions between Washington and Caracas, the Trump Administration imposed the most stringent sanctions to date on Venezuela by designating the state-owned oil company Petroleos de Venezuela, S.A.

Client Alert | January 31, 2019

2018 Year-End German Law Update

Looking back at the past year's cacophony of voices in a world trying to negotiate a new balance of powers, it appeared that Germany was disturbingly silent, on both the global and European stage.

Client Alert | January 11, 2019

Government Shutdown Update – Sanctions, Export Controls and Other International Trade Operations

The U.S. Government is now approaching the second week of a partial shutdown. The agencies responsible for administering U.S. sanctions, export controls, and other trade-related functions are among those affected, and have substantially reduced their operations.

Client Alert | January 4, 2019

New Export Controls on Emerging Technologies – 30-Day Public Comment Period Begins

On Monday, the Trump administration took the first step toward imposing new controls on the export of cutting-edge technologies.  Pursuant to the Export Control Reform Act of 2018 ("ECRA"), the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") published a request for the public's assistance in identifying "emerging technologies" essential for U.S. national security that should be subject to new export restrictions.

Client Alert | November 21, 2018

Brexit – The Draft Divorce Deal and Its Fall-Out

Negotiators for the European Union and the United Kingdom have agreed a draft withdrawal agreement that sets out how and when the UK will leave the EU (commonly known as "Brexit").  A separate, non-binding draft declaration sets out the aspirations for the future trading relationship.

Publications | November 19, 2018

Iran Sanctions 2.0: The Trump Administration Completes Its Abandonment of the Iran Nuclear Agreement

Six months ago, President Donald Trump announced his decision to abandon the 2015 Iran nuclear deal—the Joint Comprehensive Plan of Action (the "JCPOA")—and re-impose U.S. nuclear-related sanctions on the Iranian regime. The second and final wind-down period for those sanctions expired on November 5, 2018, triggering the "snap back" of remaining U.S. secondary sanctions on Iran's oil, energy, and financial sectors, among other measures. 

Client Alert | November 9, 2018

U.S. News – Best Lawyers® Awards Gibson Dunn 132 Top-Tier Rankings

U.S. News – Best Lawyers® awarded Gibson Dunn Tier 1 rankings in 132 practice area categories in its 2019 “Best Law Firms” [PDF] survey. Overall, the firm earned 169 rankings in nine metropolitan areas and nationally.

Firm News | November 1, 2018

Webcast: CFIUS Reform and the Implications for Real Estate Transactions

On August 13, 2018, President Trump signed legislation that will significantly expand the scope of inbound foreign real estate investments subject to review by the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”).

Webcasts | October 18, 2018

OFAC Issues Economic Sanctions Guidance on Digital Currencies

Over the last several months, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has expressed a clear interest in protecting the U.S. financial system from illicit activities in the digital currency space and has posited that transactions involving digital currencies be treated similarly to transactions involving traditional fiat currency.

Client Alert | October 5, 2018

U.S. Authorizes Sanctions for Election Interference

In a recent client alert we foreshadowed the Trump administration taking an aggressive stance on its sanctions policy in the lead-up to the U.S. midterm elections in November.

Client Alert | September 25, 2018

The Trump Trade Tariffs: A Roadmap for Private Equity Executives

Navigating Uncertainty and Volatility for Your Portfolio Companies As the daily headlines attest, trade tariffs – both those recently implemented and those currently pending or contemplated – continue to create a dynamic and challenging business environment, including for portfolio companies of private equity sponsors.

Client Alert | August 21, 2018

CFIUS Reform: Our Analysis

On August 13, 2018, President Trump signed the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (“FY 2019 NDAA”), an omnibus bill to authorize defense spending that includes—among other measures—legislation that will significantly expand the scope of inbound foreign investments subject to review by the Committee on Foreign Investment in the United States (“CFIUS” or “the Committee”).

Client Alert | August 14, 2018

The “New” Iran E.O. and the “New” EU Blocking Statute – Navigating the Divide for International Business

On August 6, 2018, President Donald Trump issued a new executive order authorizing the re-imposition of certain Iran-related sanctions.

Client Alert | August 9, 2018

Developments in the Defense of Financial Institutions

To Disclose or Not to Disclose: Analyzing the Consequences of Voluntary Self-Disclosure for Financial Institutions One of the most frequently discussed white collar issues of late has been the benefits of voluntarily self-disclosing to the U.S.

Client Alert | July 12, 2018

2018 Mid-Year FCPA Update

The steady clip of Foreign Corrupt Practices Act ("FCPA") prosecutions set in 2017 has continued apace into the first half of 2018, largely quieting any questions of enforcement of this important statute under the current Administration.

Client Alert | July 9, 2018

Trump Administration Revokes Primary Sanctions Relief Provided by the Iran Nuclear Agreement and Signals Strict Sanctions Enforcement

On June 27, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced it was taking further steps to implement the U.S.

Client Alert | July 2, 2018

Acting Associate AG Panuccio Highlights DOJ’s False Claims Act Enforcement Reform Efforts

On June 14, 2018, Acting Associate Attorney General Jesse Panuccio gave remarks highlighting recent enforcement activity and policy initiatives by the Department of Justice ("DOJ").

Client Alert | June 20, 2018

Revisions to the FFIEC BSA/AML Manual to Include the New CDD Regulation

On May 11, 2018, the federal bank regulators and the Financial Crimes Enforcement Network ("FinCEN") published two new chapters of the Federal Financial Institution Examination Council Bank Secrecy Act/Anti-Money Laundering Examination Manual ("BSA/AML Manual") to reflect changes made by FinCEN to the CDD regulation.

Client Alert | June 14, 2018

President Trump Issues Additional Sanctions Further Targeting PdVSA and the Government of Venezuela

On May 21, 2018, in response to the reelection of Venezuelan President Nicolás Maduro, President Donald J. Trump imposed additional sanctions against the Government of Venezuela.

Client Alert | May 31, 2018

Update on Proposed Changes to the CFIUS Review Process

After six months of wrangling over the fate of a proposal to modernize the process by which the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") reviews foreign investment in the United States, the U.S.

Client Alert | May 30, 2018

The EU Responds to the U.S. Withdrawal from the Iran Deal

A look at the European reaction to President Donald Trump's decision to re-impose certain sanctions on Iran after exiting the Iran nuclear deal, or Joint Comprehensive Plan of Action.

Client Alert | May 21, 2018

The Trump Administration Pulls the Plug on the Iran Nuclear Agreement

On May 8, 2018, President Donald Trump announced his decision to abandon the 2015 Iran nuclear deal—the Joint Comprehensive Plan of Action (the "JCPOA")—and re-impose U.S.

Client Alert | May 9, 2018

Webcast: Anti-Money Laundering and Sanctions Enforcement and Compliance in 2018 and Beyond

Gibson Dunn partners provide an overview of significant trends and key issues in Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) and sanctions enforcement and compliance.

Webcasts | May 3, 2018

FinCEN Issues FAQs on Customer Due Diligence Regulation

On April 3, 2018, FinCEN issued its long-awaited Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions, FIN-2018-G001.

Client Alert | April 23, 2018

Trump Administration Imposes Unprecedented Russia Sanctions

On April 6, 2018, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") significantly enhanced the impact of sanctions against Russia by blacklisting almost 40 Russian oligarchs, officials, and their affiliated companies pursuant to Obama-era sanctions, as modified by the Countering America's Adversaries Through Sanctions Act ("CAATSA") of 2017.

Client Alert | April 12, 2018

United States Implements Increased Tariffs on Steel and Aluminum Imports: Exclusion Relief Possible

Effective this morning, the United States implemented the increased tariffs on steel and aluminum imports that President Trump announced on March 8, 2018 in Presidential Proclamations implementing findings issued by the Commerce Department under Section 232 of the Trade Expansion Act of 1962, which allows the President to order a national security – focused investigation on the impacts of specified imports and, based upon the findings of the investigation, to impose tariffs without Congressional approval.

Client Alert | March 23, 2018

Webcast: U.S. Economic and Trade Sanctions Against Venezuela – the Outlook for 2018

This 90-minute complimentary webinar will provide a deep dive into the U.S. economic and trade sanctions against Venezuela, including a review of the most recent developments and a forecast of what may be in store for 2018.

Publications | March 13, 2018

2017 Year-End Sanctions Update

A year ago this week, we assessed that the newly-minted Trump administration could follow through on the President's campaign promises and alter several sanctions programs administered by the U.S.

Client Alert | February 5, 2018

U.S. and International Policy Convergence Brings Supply Chain Diligence on Labor Trafficking to the Fore

During the Obama Administration, a number of legal and regulatory developments placed a new premium on the importance of ensuring that supply chains did not include items produced with forced labor or otherwise involve human trafficking.

Client Alert | November 30, 2017

Trump Administration Implements Congressionally Mandated Russia Sanctions – Significant Presidential Discretion Remains

Over the past few weeks the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") and the U.S. State Department have issued their first round of guidance documents concerning how the Trump Administration will implement the "Countering America's Adversaries Through Sanctions Act" (H.R.

Client Alert | November 21, 2017

Cuba Sanctions: The Trump Administration Takes Steps to Implement Rollback of Obama Era Sanctions Relief

On November 8, 2017, the Treasury Department's Office of Foreign Assets Control ("OFAC"), the Commerce Department's Bureau of Industry and Security ("BIS"), and the State Department released amendments to the Cuban Assets Control Regulations ("CACR") and Export Administration regulations ("EAR"), effective November 9, 2017, implementing President Trump's June 16, 2017 National Security Presidential Memorandum ("NSPM"), "Strengthening the Policy of the United States Towards Cuba." Additionally, while certain transactions with Cuban parties by U.S.

Client Alert | November 16, 2017

Proposed Changes to the CFIUS Review Process

On November 8, 2017, a bipartisan group of lawmakers introduced a long-awaited bill that could significantly alter the process by which the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") reviews foreign investment in the United States.

Client Alert | November 10, 2017

Webcast: IPO and Public Company Readiness: Regulatory Compliance Issues

​Public companies face unique challenges as they confront and seek to manage OFAC, AML and FCPA compliance risk. Disclosure obligations and market reactions can intensify the pressures arising from alleged or actual violations of these laws.

Webcasts | November 1, 2017

Trump Decertifies the Iran Deal, Creating Both New Uncertainties and Potentially Unexpected Clarity

On Friday, October 13, 2017, President Trump announced a significant change in U.S. policy towards Iran by declaring his intention to refuse to certify to Congress that the 2015 Iran nuclear deal was in the national security interests of the United States.

Client Alert | October 16, 2017

In Latest Salvo, the Trump Administration Pressures Non-U.S. Companies and Persons to Cut Financial and Business Ties with North Korea

On September 20, 2017, the Trump Administration issued a new Executive Order No. 13810, imposing additional sanctions on the Democratic People's Republic of Korea ("DPRK" or "North Korea"), with dramatic implications for foreign persons involved in North Korean trade.

Client Alert | September 26, 2017

Trump Administration Rescinds Deferred Action for Childhood Arrivals (DACA) Program

On September 5, 2017, the Trump Administration announced the termination of the Deferred Action for Childhood Arrivals program ("DACA").  Attorney General Jeff Sessions announced the Administration's decision in remarks delivered on Tuesday morning.  Acting Secretary of Homeland Security Elaine Duke subsequently issued a memorandum formally rescinding the program, after which the White House issued a separate statement explaining President Trump's decision.

Client Alert | September 5, 2017

President Trump Issues New Sanctions Targeting Certain Activities of PdVSA and the Government of Venezuela

Continuing an active month of increased sanctions pressure on Venezuela, on August 24, 2017, President Donald J. Trump issued an executive order imposing a unique set of sanctions targeting transactions involving debt and equity of the Venezuelan government, including Venezuela's state-owned oil company Petroleos de Venezuela, S.A.

Client Alert | September 1, 2017