Grants and tax credits, who doesn’t love them? The Bipartisan Infrastructure Law (BIL) is full of them, and recent Department of Energy (DOE) Notification of a Proposed Interpretive Rule provides guidance on who will get to benefit from those grants and tax credits. The BIL is a historic investment in U.S. infrastructure, the breadth of which is beyond the scope of this blog. However, thankfully, the DOE Proposed Rule focuses on batteries.Continue Reading Should You Be Concerned About Foreign Entities of Concern?
Jordan Mallory is an associate in the Governmental Practice in the firm's Washington, D.C. office.
On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter…Continue Reading New Russia Sanctions Intensify Pressure on Banks Worldwide
Export controls are the manifestation of foreign, economic, and national security policy, and the implementation of policy requires dynamic adjustment, a back-and-forth, a balance. So, on December 7, 2023, amid the tightening of new semiconductor regulations, BIS announced it was relaxing regulations around another set of exports. This drawing back of the controls arrives in the form of a set of three rules easing license requirements and expanding license exceptions. While seemingly disparate, each of the three areas of amendments represents a consistent push to align U.S. export policy with those of its allies and trade partners, as well as to reward those allies with (slightly) less burdensome controls.Continue Reading Carrot and Stick Export Controls: U.S. Export Controls Give Benefits to Allies
On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger comprehensive settlement with the Department of Justice, FinCEN, and the CFTC, totaling over $4 billion. OFAC found that Binance had allowed 1.6 million transactions in violation of multiple sanctions regimes while Binance’s C-Suite was complicit. Binance’s blunders that led to this enforcement action highlight the importance of management commitment to compliance programs.Continue Reading Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History