National Security and International Trade Update

Key developments at the intersection of security and commerce.

1
Welcome to Our New Blog
2
European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry
3
European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry
4
Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners
5
EU Sanctions—Article 8a “Best Efforts” Explained
6
New Executive Order Bolsters the Nation’s Cyber Defenses
7
New US Sanctions Target Russia’s Energy Sector
8
Preparing for New Trump Tariffs: 10 Approaches
9
Final Rule on Outbound Investments: Implications for Limited Partner Investments
10
Trump Signals First-Day Tariff Hikes Targeting China, Canada, and Mexico
11
Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

Welcome to Our New Blog

By: Steven F. Hill

Welcome to the K&L Gates National Security and International Trade Update, a product of our global international trade and national security practices.

We hope you will find this a valuable resource for the latest developments on policies and regulations arising from global national security and international trade considerations.

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European Union Adopts 16th Package of Sanctions Against Russia, Further Impacting the Aviation Industry

By: Laura Scott, Petr Bartos, and Michael Ruck

On 24 February 2025, the European Union adopted the 16th Russia sanctions package.

The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395. They target systemically important sectors of the Russian economy including energy, trade, transport, infrastructure and financial services. The new package also includes restrictions directly impacting the aviation industry, through the amendment to Article 3d, “the flight ban”, and the inclusion of Article 5ae, “a full transaction ban” on ports and airports in and surrounding Russia.
Below you will find a very brief note on the beforementioned articles.

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Trump Administration Directs CFIUS to Tighten Restrictions on Investment From Certain Countries While Easing National Security Reviews of Investments From Allies and Partners

By: Guillermo S. Christensen, Steven F. Hill, Brian J. Hopkins, Dave R. Allman, Nate B. Bolin, and Jeffrey Orenstein

On 21 February 2025, President Donald J. Trump issued the America First Investment Policy, directing the Committee on Foreign Investment in the United States (CFIUS) to adjust its approach to foreign investments. This policy aims to facilitate investments from allied nations while imposing stricter reviews on investments from adversarial countries, particularly China.

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EU Sanctions—Article 8a “Best Efforts” Explained

By: Michael E. Ruck, Petr Bartoš, and Helen J. Phizackerley

On 24 June 2024, the European Union (EU) implemented its 14th package of sanctions against Russia to combat its continued aggression against Ukraine. A notable addition was made to Article 8a of Council Regulation (EU) No 833/2014, which introduced the requirement that EU operators “undertake their best efforts to ensure that any legal person, entity or body established outside the Union that they own or control does not participate in activities that undermine the restrictive measures provided for in [the] Regulation.” A similar clause has also been included in the Belarus sanctions framework.

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New Executive Order Bolsters the Nation’s Cyber Defenses

By: Sheila Armstrong, Corey Bieber, Guillermo Christensen, Brian Hopkins, and J.D. Koesters

In a significant move to bolster the United States’ cybersecurity framework, President Biden issued an executive order (EO) on 16 January 2025 titled “Strengthening and Promoting Innovation in the Nation’s Cybersecurity” days before leaving the White House. This comprehensive directive outlines measures designed to enhance the security of federal systems, improve transparency in third-party software supply chains, and leverage emerging technologies to fortify cyber defenses.

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New US Sanctions Target Russia’s Energy Sector

By: Nate Bolin, Jeffrey Orenstein, Myeong Park, and Brian Hopkins

On 10 January 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a package of new sanctions targeting Russia’s energy sector. In an effort to curtail Russia’s oil revenue and ability to evade US sanctions, OFAC issued: (1) a Determination authorizing sanctions on parties operating in Russia’s energy sector; (2) a Determination banning US petroleum services to Russia; and (3) blocking sanctions against oil and gas majors, vessels in the so-called “shadow fleet,” certain traders of Russian oil, Russian maritime insurers, and Russian oilfield service providers.

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Final Rule on Outbound Investments: Implications for Limited Partner Investments

By: Steven F. Hill, Nathaniel B. Bolin, and Myeong S. Park

Introduction

On 28 October 2024, the US Treasury Department issued a Final Rule implementing the Outbound Investment Program (OIP) under Executive Order 14105, which safeguards US national security by limiting investments by US persons in key technologies in “countries of concern,” specifically China including Hong Kong and Macau. Effective 2 January 2025, the OIP targets outbound investments in Semiconductors and Microelectronics, Quantum Information Technologies, and Artificial Intelligence by prohibiting certain transactions and permitting other transactions subject to a notification requirement (together, “covered transactions”).

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Trump Signals First-Day Tariff Hikes Targeting China, Canada, and Mexico

By: Nate Bolin, Dave Allman, and Brian Hopkins

On 25 November, President-Elect Donald Trump announced plans to impose substantial tariffs on goods from China, Mexico, and Canada through executive action, signaling a return to his aggressive trade policies. If implemented, these measures could have significant implications for businesses reliant on international supply chains.

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Top Tips for Sanctions Compliance and Preventing Sanctions Evasion

By: Michael Ruck, Petr Bartoš, and Helen Phizackerley

On 24 September 2024, the G7 released updated guidance on the prevention of evasion of export controls and sanctions imposed on Russia.

This blog provides an overview of the guidance and the firm’s top tips for sanctions compliance and preventing sanctions evasion:

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