Key developments at the intersection of security and commerce.
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.
Read MoreBy: Michael Ruck, Rosie Naylor, and Laura Scott
In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has highlighted key findings surrounding suspected sanctions breaches involving UK legal services providers since February 2022 (the Assessment).
Legal services providers play a crucial role in ensuring UK and international clients (including UK Designated Persons (DPs)) comply with UK financial sanctions as well as other threats to compliance relevant to the United Kingdom.
The Assessment sets out four key findings relevant to the UK legal services providers from February 2022 to present.
The Assessment highlighted a series of red flags for lawyers to look out for, especially when an “intermediary jurisdiction” was involved.
Legal services providers should take the following steps, amongst others, to ensure compliance with the UK sanction regime:
OFSI encourages legal services providers to both report now and retrospectively (using this channel), where appropriate and proportionate, if they suspect a breach has occurred.
For further information, please see our corresponding alert.
By: Steven F. Hill, Guillermo S. Christensen, Jeff Orenstein, and Brian J. Hopkins
On 24 March 2025, the White House issued an Executive Order threatening to impose a 25% tariff on all goods imported into the United States from any country that imports Venezuelan oil directly or indirectly through third parties. Effective on or after 2 April 2025, the tariff is in response to alleged actions of Venezuela’s Maduro government, in particular sending members of the Tren de Aragua gang (designated a foreign terrorist organization) and other criminals into the United States and its involvement in kidnapping and violent attacks including the assassination of a Venezuelan opposition figure.
Read MoreBy: Laura Scott, Petr Bartos, and Michael Ruck
On 24 February 2025, the European Union adopted the 16th Russia sanctions package.
Read MoreBy: 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.
Read MoreBy: 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.
Read MoreBy: 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.
Read MoreBy: 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.
Read MoreBy: Jeffrey Orenstein, Karla Cure, and Brian Hopkins
Here are 10 ways to avoid, mitigate, or delay the costs of new tariffs that President-elect Trump has promised for countries like China, Canada, and Mexico:
Read MoreBy: Steven F. Hill, Nathaniel B. Bolin, and Myeong S. Park
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”).
Read MoreBy: 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.
Read MoreCopyright © 2025, K&L Gates LLP. All Rights Reserved.