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At Husch Blackwell, Emily focuses on export controls, economic sanctions and related government investigations. She advises clients in a wide array of industries on the specifics of trade regulations, analyzing the effects of rules and restrictions on businesses as they import and export goods and materials.

On April 24, 2024, President Biden signed into law the 21st Century Peace through Strength Act, Pub. L. No. 118-50, div. D. Part of the Act included a provision extending the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) from five years to 10 years. The new statute of limitations took effect on the date of the President’s signature.

Recently, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new guidance to exporters intended to further assist BIS in its efforts to crack down on third-party diversion to Russia.

Specifically, BIS’s recent guidance outlines the various mechanisms it has employed—outside of its usual public screening lists (i.e., the Unverified List

On June 20, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a Final Determination prohibiting the sale of certain cybersecurity products, anti-virus software, and related services to U.S. persons by Kaspersky Lab, Inc. (“Kaspersky”), the U.S. subsidiary of Russian cybersecurity provider AO Kaspersky Lab.

This Final Determination represents the first

On July 10, 2024, the Biden Administration announced tariff increases on imports of aluminum  and steel products. The tariff increases are the latest measure to combat the circumvention of Section 301 duties imposed against Chinese origin products by shipping the products through third countries.

The modifications apply to goods entered or withdrawn for consumption

Sanctions Designations and Business Advisory Issued by OFAC and the U.S. State Department

On February 23, 2024, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and Department of State together announced more than 500 sanctions designations targeting government officials, companies, and individuals in Russia and beyond.  The sanctions, which the U.S. stated were intended

Executive Order Imposes New Russia Sanctions for Foreign Financial Institutions and Prohibits Additional Russian Imports

On December 22, 2023, President Biden issued Executive Order 14114, which amended previous Executive Orders in order to authorize the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to impose additional Russia-related sanctions on foreign financial institutions and

As of Friday September 29, 2023, the United States Congress has yet to reach a spending agreement, as a result companies with international trade operations should prepare for a potential Federal government shutdown. The shutdown, which is expected to take place beginning as of 12:01 am October 1, 2023, will cause significant changes to international

On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national security laws. The Compliance Note highlights the new changes made to the Department of Justice’s voluntary self-disclosure policy. The Note also provided an overview

On June 22, 2023, the United States Trade Representative (USTR) announced that the United States and India reached an agreement to terminate ongoing  disputes at the World Trade Organization (WTO). Additionally, India agreed to remove retaliatory tariffs implemented against certain U.S. products in response to the U.S.’s institution of Section 232 tariffs on steel and

On Friday, May 19, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the addition of more than 300 Russian Federation individuals and companies as well as other individuals and companies alleged to be aiding Russia’s war efforts to the Specially Designated Nationals and Blocked Persons (“SDN”) List. Simultaneously, the U.S.