Cross-Border Compliance Update

Cross-Border Compliance Update: May 2020

June 9, 2020

Foley Hoag’s Trade Sanctions & Export Controls Practice offers experienced, proactive regulatory advice to help clients avoid regulatory compliance missteps and to prevail in official proceedings. For more information about global compliance, visit the Foley Hoag Trade Sanctions & Export Controls Practice Group.

Included in this Issue:

  • Proposed Rules on CFIUS Mandatory Declarations Released: No More NAICS Codes!
  • New Prohibitions on Foreign-Produced Exports to Huawei
  • New Executive Order Restricts Foreign Investment in Bulk-Power System
  • Human Rights Protections for Uighur and Minority Groups in China
    • Uyghur Human Rights Policy Act Passes Senate
    • New Entity List Designations for Human Rights Abuses in the Xinjiang Uighur Autonomous Region
  • North Korean and Chinese Bankers Indicted in $2.5 Billion Money Laundering Scheme
  • Sanctions Advisory Issued for the Maritime Industry, Energy and Metals Sectors, and Related Communities
  • Sanctions Updates
    • Iran: Sanctions on Chinese Company for Assisting Mahan Airline
    • Iran: Twelve Iranian Officials and Entities Sanctioned
    • Nicaragua: Sanctions on Senior Government Officials
    • State Department Designation of Former Official of Bosnia and Herzegovina for Corruption
    • Zimbabwe: Removal of General License No. 1
  • CFIUS Releases Annual Report to Congress for 2018
  • CBP Issues Detention Order on Seafood Harvested with Forced Labor


Proposed Rules on CFIUS Mandatory Declarations Released: No More NAICS Codes!

On May 21, 2020, the Department of the Treasury released a proposed rule that would modify the requirements for Committee on Foreign Investment in the United States (CFIUS) mandatory declarations. This proposed change includes removing the North American Industry Classification System (NAICS) codes criteria. These changes have been anticipated since new CFIUS regulations went into effect on February 13, 2020 and the Department of the Treasury announced that future changes regarding mandatory declarations for critical technology transactions were forthcoming. Written comments on the proposed rule must be submitted by June 22, 2020.

Download the May 2020 Foley Hoag Cross-Border Compliance Update (pdf).