On May 15, 2024, the Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 was laid before parliament (“Regulations”).  Among other things, the Regulations included a package of new trade sanctions measures under the UK’s Belarus sanctions regime targeting aluminum, as well as expanding sanctions on electronics (including semiconductors, electronic integrated circuits, and the machinery / apparatus needed for their manufacture), navigational instruments and appliances, aircraft, spacecraft and related parts.  The new trade sanctions came into effect on May 16, 2024.Continue Reading UK Imposes New Trade Sanctions on Belarus

On February 24, 2023, the US government announced a range of new export controls, sanctions, and tariffs to coincide with the first anniversary of Russia’s ongoing war against Ukraine. These actions by the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), the US Department of State, and the White House reflect the continued efforts of the US – in coordination with its allies – to impose costs on Russia for the war.

Each successive round of US export controls and sanctions presents new compliance challenges, against the backdrop of heightened enforcement risk resulting from aggressive, well-coordinated US government actions. US and non-US entities and individuals who engage in transactions related to Russia or Belarus should pay close attention to this complex and evolving regulatory framework. Additionally, entities and individuals exporting to Iran should take note of the expanded scope of the US Export Administration Regulations (EAR) under a new Iran Foreign Direct Product (FDP) Rule.Continue Reading US Imposes Additional Export Controls, Sanctions, and Tariffs targeting Russia, Belarus, and Iran On First Anniversary of Russia’s War Against Ukraine

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently released preliminary guidance on the implementation of a price cap policy on Russian crude oil and petroleum products.  This policy has major implications for maritime service providers and maritime supply chains.
Continue Reading OFAC Releases Preliminary Guidance on Implementation of the Russian Oil Price Cap

On April 20, 2021, the US Department of Energy (“DOE”) revoked a December 2020 Prohibition Order issued by the Trump Administration which banned the acquisition, importation, transfer, or installation of certain bulk-power system (“BPS”) electric equipment manufactured or supplied by “persons owned by, controlled by, or subject to the jurisdiction or direction of the {People’s Republic of China (“China”)}.”  The Prohibition Order was issued pursuant to EO 13920, “Securing the United States Bulk-Power System” (May 1, 2020), which was promulgated to address “foreign adversary countries creating and exploiting vulnerabilities in the United States bulk-power system.”  In response to this alleged exploitation, the EO declared an emergency and authorized the Secretary of Energy to prohibit transactions involving certain BPS electric equipment sourced from “foreign adversary” countries for one year. In the recent revocation notice, DOE cited the need to “create a stable policy environment” while the Department conducts a new review of how best to apply its EO 13920 authorities.

On January 20, 2021, the Biden Administration suspended EO 13920 for a period of 90 days to afford the Secretary of Energy and Director of the Office of Management and Budget time to consider whether to recommend a replacement Executive Order that “appropriately balances national security, economic, and administrability considerations,” Pursuant to last week’s Request for Information, DOE is now soliciting comments from electric utilities, academia, research laboratories, government agencies, and other stakeholders on various aspects of electric infrastructure.  Specifically, DOE is soliciting comments on the following questions concerning the development of a long-term strategy:Continue Reading US Department of Energy Revokes Trump Prohibition Order Restricting Chinese Bulk-Power System Electric Equipment and Seeks Comments on Securing US Critical Electric Infrastructure

Steptoe’s International Trade and Investment Group is excited to announce the launch of its Global Trade Policy Blog. The blog will cover trade remedies, trade policy, investor-state arbitration, customs, trade negotiations and the World Trade Organization (WTO), and will provide information on developments in the United States, the EU and in jurisdictions around the

On May 29, President Trump announced in a White House news conference the US government would “begin the process” to revoke the “full range of agreements” providing the Hong Kong Special Administrative Region of China separate treatment from mainland China under US law on topics including “export controls on dual use technologies,” among others, “with

On Friday, May 1, President Trump issued an Executive Order declaring a national emergency with respect to the threat posed to the United States bulk-power system by certain equipment potentially liable to exploitation by “foreign adversaries.” Under the Executive Order, certain foreign-supplied equipment used in the US bulk-power system will be subject to US government

A recent letter from former high-ranking European Commission officials to the current Commission President Ursula von der Leyen raises various trade and market protection concerns and urges the Commission to take certain actions.

The letter raises legitimate areas of concern both as regards the current crisis in global trade and EU trade policy more generally.

On Tuesday, May 19, the Department of Commerce issued a Notice requesting comments on a newly initiated Section 232 national security investigation into electrical transformers, and key components of the transformers, which we addressed earlier in one of our blog posts. The investigation focuses on liquid and dry transformers above 1 KVA power handling capacity. As set forth in the notice: “[T]he investigation has been undertaken to determine the effect on the national security of imports of Laminations for Stacked Cores for Incorporation into Transformers, Stacked Cores for Incorporation into Transformers, Wound Cores for Incorporation into Transformers, Electrical Transformers, and Transformer Regulators (hereinafter “Products”). If the Secretary finds that Products are being imported into the United States in such quantities or under such circumstances as to threaten to impair the national security, the Secretary shall so advise the President in his report on the findings of the investigation.” Continue Reading Commerce Seeks Comments in National Security Investigation Involving Imports of Electric Transformers, Key Components of Transformers

On Friday, May 1, President Trump issued Executive Order (EO) 13920, “Securing the United States Bulk-Power System.” In EO 13920, the President declared a national emergency under the International Emergency Economic Powers Act (IEEPA) with respect to the threat posed to the US bulk-power system (BPS) by equipment liable to exploitation by “foreign adversaries.”

The EO directs the secretary of energy, in coordination and consultation with other heads of agencies, to impose restrictions on transactions involving bulk power system electric equipment that could raise national security concerns. Furthermore, the EO broadly delegates implementation authority to the secretary of energy, who is required to publish rules and regulations to implement the EO within 150 days, or by September 28.Continue Reading Client Advisory: Trump Administration Pursues Restrictions to Secure US Electricity Grid