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As we close out a wild year for international trade regulation,[1] after hearing much talk about outbound investment review mechanisms, we may see a final dramatic change before the ball drops. Since the summer, we have talked here about potential outbound investment reviews (reverse CFIUS? SUIFC?). And while there have been reports of potential action by both Congress and the Biden Administration on outbound investment, it is all the more possible to see executive action before a new Congress takes seat.…

Continue Reading Will We Ring in the New Year with Outbound Investment Restrictions?

After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately, since the end of sanctions is a long way away.
Continue Reading Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?

By: Scott Maberry and Mark Jensen

People who practice U.S. economic sanctions law like to talk about how sanctions are policy-oriented, or an engine of U.S. foreign policy.  Whereas some laws may be more opaquely political, economic sanctions and embargoes seem to express most bluntly how international leverage works through regulation.  And yet, a few recent regulatory developments show that the direction that sanctions take is not always predictable.
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Continue Reading OFAC Gets Hot, Bothered on Iran and Cuba: How Economic Sanctions Work Today