On December 27, 2024, the U.S. Department of Justice, National Security Division (“DOJ”) issued a final rule implementing a new regulatory program designed to prevent certain countries (China, Cuba, Iran, North Korea, Russia, and Venezuela) and covered persons from having access to Americans’ bulk sensitive personal data and U.S. government-related data (“Final Rule”).[1] The Final Rule, which implements Executive Order (“E.O.”) 14117 issued on February 28, 2024, builds on an Advanced Notice of Proposed Rulemaking published March 5, 2024, which we previously discussed here, and a Notice of Proposed Rulemaking published on October 29, 2024.[2] The Final Rule will enter into effect on April 8, 2025. However, certain due diligence, audit, and reporting requirements will not require compliance until October 6, 2025. Continue Reading DOJ Issues Final Rule Targeting Bulk Sensitive Personal and U.S. Government-Related Data Transactions Involving Countries of Concern
North Korea
Compromise U.S. Defense Bill Provides for New Secondary Sanctions Against Russia, Syria, and North Korea
By Paul Marquardt & Samuel H. Chang on
On the evening of December 9, 2019, a U.S. congressional conference committee released the compromise version of the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020” or “Defense Bill”). NDAA 2020, which will be voted upon without further amendment and is virtually certain to be enacted into law, contains provisions that would authorize new secondary sanctions relating to the Nord Stream 2 and TurkStream projects, Syria, and North Korea.
Continue Reading Compromise U.S. Defense Bill Provides for New Secondary Sanctions Against Russia, Syria, and North Korea
Sanctions Outlook: Congress to Consider Sanctions Provisions in FY2020 Defense Bill
By Paul Marquardt & Samuel H. Chang on
Over the last few weeks, the U.S. House and Senate have separately passed a number of amendments to the National Defense Authorization Act for Fiscal Year 2020 (the “NDAA”) that, if enacted, would expand sanctions on persons and activities related to North Korea, China, Russia, Burma, and certain Central American states.
Continue Reading Sanctions Outlook: Congress to Consider Sanctions Provisions in FY2020 Defense Bill
United States Imposes Secondary Sanctions on Dealings with North Korea
By Paul Marquardt on
Posted in North Korea, Sanctions
On September 20, 2017, President Trump issued Executive Order 13810, imposing additional sanctions against North Korea. Most notably, the new Executive Order provides for a “secondary sanctions” regime, threatening to impose U.S. sanctions against persons engaging in targeted transactions (whether or not they have any connection to the United States).
Continue Reading United States Imposes Secondary Sanctions on Dealings with North Korea