Alexis Early

Alexis Early

Alexis Early counsels multinational corporations, financial institutions, and individuals on economic sanctions compliance, the release of erroneously blocked assets, export controls, and CFIUS national security reviews of inbound foreign investments, and the impact of legislation pending before Congress.  She has experience representing clients in compliance and enforcement proceedings before the Treasury Department, State Department, Commerce Department, and Department of Homeland Security.  Prior to joining Steptoe, Ms. Early advised corporations and foreign sovereigns on international trade, defense cooperation, and rule of law issues, and advocated on their behalf before Congress.

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US Ratchets up Pressure on North Korea by Targeting Chinese Supporters

President Trump’s recent exasperated tweet at China – suggesting China is not doing enough to stop North Korea’s nuclear efforts and rogue behavior – was followed last week by financial sanctions on Chinese supporters of North Korea.  On June 29, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) placed on its list of Specially … Continue Reading

OFAC Removes Burmese Sanctions Regulations

On June 16, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it removed the Burmese Sanctions Regulations (“BSR”) from the Code of Federal Regulations.  This removal is the culmination of actions taken by the Obama Administration in October 2016 to terminate the national emergency with respect to Myanmar (EO … Continue Reading

Trump Administration Considers National Security Implications of Steel Imports

On April 19, the Trump administration took action under a rarely-used provision of the Trade Expansion Act of 1962, allowing the United States to impose tariffs if it determines that certain imports pose a national security threat.  Acting under section 232 of the Trade Expansion Act, the Department of Commerce announced the start of an … Continue Reading

Congressional CFIUS Round-Up

The Committee on Foreign Investment in the United States (“CFIUS”) review process has long been a creature of the executive branch, but members of the House and Senate are increasingly trying to exert their influence over CFIUS in 2017—and it is Chinese and Russian investors who are first and foremost in Congress’s sights. On April … Continue Reading

New Iran Sanctions Bills Backed by Bipartisan Group of Key Legislators

On March 23, 2017, members of Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. While several Iran sanctions bills have been introduced since the start of the year, these newly introduced bills are particularly notable due to their bipartisan support from an influential group of legislators. The bills represent legislative compromises … Continue Reading

ZTE Enters Multi-Agency Settlement to Resolve Sanctions and Export Controls Allegations

On March 8, 2016, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added major Chinese telecommunications company Zhongxing Telecommunications Equipment (“ZTE”) and three ZTE affiliates to the BIS Entity List, alleging that the ZTE entities developed a scheme to re-export controlled items to Iran in violation of US export controls and sanctions … Continue Reading

Generation Shift: Recent Developments in US-China Business Relations and the Path Ahead Under President-elect Trump

The US-China relationship is conceivably the most significant and complex bilateral relationship of the early 21st century, largely because China is the greatest US trading partner that is not a strategic ally.  US-China competition regarding security and global influence can drive innovative solutions or hamper trade and other areas of cooperation.  Please see our advisory … Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

Iran Sanctions Extension Act Becomes Law without President Obama’s Signature

On December 15, 2016, the White House Press Secretary released a statement that President Obama would allow the Iran Sanctions Extension Act (H.R. 6297) to become law, but that the President declined to sign it.  This bill extends the current Iran Sanctions Act (ISA) through December 31, 2026 and passed Congress with overwhelming support, passing the … Continue Reading

BIS Again Extends ZTE Temporary General License

On November 18, 2016, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it extended its temporary general license for exports, reexports, and in-country transfers to Zhongxing Telecommunications Equipment Corporation (ZTE Corporation) and ZTE Kangxun.  The temporary general license benefitting these two ZTE entities was scheduled to expire on November 27, 2016, … Continue Reading

Two Questions and Partial Answers About What a Trump Administration Could Mean for CFIUS

The Committee on Foreign Investment in the United States (“CFIUS”) is a powerful tool of the executive branch.  CFIUS effectively can impose conditions on, block, or even unwind foreign investments in U.S. companies.  But the tool has been wielded, thus far, only to safeguard U.S. national security. Two common questions about CFIUS, in view of … Continue Reading

Deadline Approaches for Facility Security Clearance Holders to Implement Insider Threat Procedures

As Steptoe previously reported, May 2016 the DoD published updates to the National Industrial Security Operating Manual (“NISPOM,” Change 2 to DoD 5220.22-M) and an accompanying Industrial Security Letter requiring government contractors holding a facility security clearance (“FCL”) to establish or maintain a written policy by November 30, 2016 to detect, deter, and mitigate insider … Continue Reading

How the 2016 Election Will Impact Public Policy Developments

Sunday’s presidential town hall debate was the second of three opportunities for candidates Donald Trump and Hillary Clinton to make their case to the American electorate.  In addition to the discussion of personal and character issues, the candidates touched on a range of policy issues, including tax policy, financial services, energy, and international trade.  The … Continue Reading

When is the Right Time to Make a CFIUS Filing?

Foreign investors in US companies often must consider multiple regulatory issues.  Among those is whether to seek clearance from the Committee on Foreign Investment in the United States, or CFIUS.  A related question is when to file with CFIUS.  Comparatively little guidance is available on the latter question.  To learn more about whether and when … Continue Reading

Customer Due Diligence Guidance by FinCEN for Certain Financial Institutions

On July 19, 2016, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Frequently Asked Questions to clarify the scope of its rule, “Customer Due Diligence (CDD) Requirements for Financial Institutions.”  Steptoe’s International Compliance Blog covered the rule in May. This rule took effect on July 11, 2016, but does not require … Continue Reading

US and EU Dissuade Banks from Participating in Russian Bond Offering

US and EU regulators have warned banks not to participate in a proposed $3 billion, 10-year Russia Eurobond offering, even if participation will not technically violate US sanctions laws targeting Russia based on its annexation of Crimea and destabilization of eastern Ukraine.  Russia reportedly invited European and Chinese banks to bid on the proposed offering, … Continue Reading

Treasury Announces Anti-Money Laundering, Corruption, and Tax Evasion Regulations and Legislation

On May 5, 2016, the US Department of the Treasury announced several actions to crack down on illicit financial conduct and increase transparency in the financial system.  First, Treasury will publish a Customer Due Diligence (“CDD”) Final Rule.  This rule will harmonize and clarify existing anti-money laundering due diligence requirements and also add a new … Continue Reading

Halliburton Settlement Shows Risks of Dealing with Entities Partially Owned by Sanctioned Entities

On February 25, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it concluded an enforcement action against Halliburton Atlantic Limited (“HAL”) and its affiliate Halliburton Overseas Limited (“HOL”) for alleged violations of the Cuban Assets Control Regulations (“CACR”). HAL and HOL are both Cayman Islands-headquartered subsidiaries of U.S. … Continue Reading

Congress Expected to Pass Visa Bill with JCPOA Implications

On December 15, 2015, Speaker of the House Paul Ryan (R-WI) announced that Congress reached agreement on a $1.1 trillion FY 2016 omnibus spending bill (HR 2029), which included a controversial provision that could have implications for the Joint Comprehensive Plan of Action (“JCPOA”).  Division O, Title II contains the Visa Waiver Program Improvement and … Continue Reading

OFAC Finding of Sanctions Violation Prompts Guidance on “False Hit Lists”

On October 21, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Finding of Violation against BMO Harris Bank as the successor to Marshall and Ilsley Bank, which originated over $67,000 in funds transfers in 2011 on behalf of an entity involved in importing Iranian-origin carpets.  The bank had previously processed … Continue Reading

What’s Sanctions Got to Do with It? Why Understanding US Sanctions Is Critical for International Business Deals

What factors must companies consider when engaging in international mergers and acquisitions?  Although there has been much fanfare about President Obama’s announced relaxation of the Cuban embargo and plans to roll back Iran sanctions, many sanctions traps remain for the unwary. In their article “What’s Sanctions Got to Do with It?  Why Understanding US Sanctions … Continue Reading

The JCPOA and State Sanctions Laws, Part 2

As discussed in Bibek Pandey’s previous post, the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA) authorizes states to enact laws: (i) requiring state public funds to divest from companies doing certain types of business in Iran; and (ii) prohibiting states from entering into procurement contracts with such companies.  To date, nearly half of the … Continue Reading