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Articles by E. Gilman
BIS Eases US Export Controls For UAE: Key Opportunities & Compliance Considerations
On July 14, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule, Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations (the Rule), significantly improving the United Arab Emirates (UAE)’s status under the Export Administration Regulations (EAR).
US–Iran Sanctions Update: OFAC Issues General License X Following Signing Of Memorandum Of Understanding
On June 22, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License X (GL X), authorizing a broad range of transactions involving Iranian-origin crude oil and related products, following the June 17, 2026 signing of a 14-point Memorandum of Understanding (MOU) between the United States and Iran that established a framework for de-escalation and targeted sanctions relief.
OFAC Issues General Licenses Authorizing Activities Involving The Venezuelan Oil Sector
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued several Venezuela-related general licenses, authorizing activities that would otherwise be prohibited under the Venezuela Sanctions Regulations under 31 CFR part 591 (VSR) and that are essential to supporting the production of heavy Venezuelan crude oil. General License No. 46A, issued on Feb. 10, 2026, authorizes certain activities involving Venezuelan-origin oil; General License No. 47, issued on Feb.
FCC Adopts New Foreign Adversary Attestation And Disclosure Rules Impacting Satellite Operators And Submarine Cable Landing Licensees
GT Greenberg Traurig, LLP More Greenberg Traurig, LLP has more than 3000 attorneys across 51 locations in the United States, Europe, the Middle East, Latin America, and Asia. The firm’s broad geographic and practice range enables the delivery of innovative and strategic legal services across borders and industries.
OFAC Issues General Licenses Authorizing Activities Involving the Venezuelan Oil Sector
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued several Venezuela-related general licenses, authorizing activities that would otherwise be prohibited under the Venezuela Sanctions Regulations under 31 CFR part 591 (VSR) and that are essential to supporting the production of heavy Venezuelan crude oil. General License No. 46A, issued on Feb. 10, 2026, authorizes certain activities involving Venezuelan-origin oil; General License No. 47, issued on Feb.
Syria Market Reentry: FY 2026 NDAA Opens Doors, But Risk Management Is Key | JD Supra
[co-authors: Joshua Johnson, Megan Thomas*] Bottom Line Repeal of the Caesar Act eliminates broad sanctions regimes on certain business activities in or with Syria. While this creates new commercial opportunities in Syria, other US sanctions, designations, and regulations still apply. Companies considering operations in Syria are encouraged to proactively manage risk and ensure their compliance programs are up to date by accounting for the nuanced risks associated with Syria.
America First enforced: Recent FCPA action reflects administration priorities | JD Supra
On November 10, 2025, the US Department of Justice (DOJ) entered into a two-year deferred prosecution agreement (DPA) with a foreign telecommunications company, marking the first criminal corporate resolution since the Trump Administration lifted its enforcement “pause” on the Foreign Corrupt Practices Act (FCPA) earlier this year.1 The DPA exemplifies the practical application of all the enforcement guidance released by the Administration this year, including the benefits available to...
US Department of Commerce issues milestone RFI for the American AI Export Program | JD Supra
On October 22, 2025, the US Department of Commerce announced the establishment of the American AI Export Program (AI Export Program), the Trump Administration’s first action under President Donald Trump’s July 2025 Executive Order 14320, “Promoting the Export of the American AI Technology Stack” (AI Export Order).
DOJ declines prosecution for PE firm after post-acquisition voluntary self-disclosure | JD Supra
On October 4, 2023, the DOJ announced a new policy to promote prompt reporting of misconduct discovered at acquired companies by providing a safe harbor to acquirer companies that voluntarily self-disclose misconduct at an acquired company “within six months from the date of closing.” On March 7, 2024, the NSD followed up this announcement by publishing its new NSD M&A Policy.
OFAC sanctions and FinCEN Advisory target Iran’s shadow banking infrastructure | JD Supra
On June 6, 2025, the US Department of the Treasury’s (Treasury) Office of Foreign Assets Control (OFAC) sanctioned over 30 individuals and entities believed to be tied to a network that laundered billions of dollars on behalf of the Iranian regime. The network used Iranian exchange houses and numerous United Arab Emirates (UAE)- and Hong Kong-based front companies under their control as part of what is referred to as Iran’s “shadow banking” network.
DOJ releases new corporate crime enforcement guidance, telling companies what to expect—and how to avoid criminal penalties | JD Supra
That same day, Matthew R.
Executive Order signals major shift in FCPA enforcement—for now | JD Supra
The Executive Order directs the Attorney General to take several actions over the next 180 days (and grants the Attorney General authority to extend the review period for an additional 180 days as necessary). Specifically, the Executive Order directs the Attorney General to: Cease initiating new FCPA investigations and enforcement actions.
DOJ emphasizes importance of AI risk mitigation, whistleblower protections, and clawback compensation policies | JD Supra
Last Monday, the Department of Justice (the DOJ or the Department) announced significant updates to the DOJ Criminal Division’s Evaluation of Corporate Compliance Programs (ECCP).1 These updates discuss, for the first time, the importance of mitigating specific risks associated with the use of artificial intelligence (AI). The updates also reiterate the Department’s focus on whistleblower protections and clawback compensation policies.
Treasury proposes expansion of CFIUS authorities | JD Supra
On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In recent months, the US government has taken a number of actions to further enhance the enforcement of US national security objectives. The Proposed Rule is another example of the US government prioritizing and refining its national security authorities.
More carrots, more sticks - DOJ announces agency-wide whistleblower pilot program | JD Supra
The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.”1 The new whistleblower pilot program, which is still under development, will incentivize individuals with monetary rewards to disclose corporate wrongdoing to the DOJ.
SDNY announces new whistleblower program, continuing Justice’s push for self-disclosure | JD Supra
“Call us before we call you.”1 With this message, on January 10, 2024, the Southern District of New York announced the SDNY Whistleblower Pilot Program (Pilot Program), which seeks to encourage individual participants in certain types of criminal conduct to voluntarily self-disclose and cooperate with prosecutors.2 The announcement echoed a nearly identical message delivered by the Department of Justice’s (DOJ) Criminal Division in November 2023,3 further emphasizing the growing importance of...
Bitcoin ETF approvals come with stark warning from SEC Chair | JD Supra
“While we approved the listing and trading of certain spot bitcoin ETP shares today, we did not approve or endorse Bitcoin…. Investors should remain cautious about the myriad risks associated with Bitcoin and products whose value is tied to crypto.”—SEC Chair Gary Gensler Notwithstanding Mr. Gensler’s warning, he, along with two other Commissioners, voted last week to approve 11 exchange-traded funds (ETFs) holding Bitcoin for the first time since the inception of cryptocurrency.
Financial institutions on the front lines of combating terrorist financing | JD Supra
Immediately following the October 7 attack by Hamas on Israel, the United States Financial Crimes Enforcement Network (FinCEN) announced the creation of the Counter Terrorist Financing Taskforce— Israel (CTFTI)—a coalition of global financial intelligence units (FIUs) of the United States, the United Kingdom, Israel and at least 10 other allied nations.
The highly-anticipated US Executive Order on artificial intelligence: Setting the agenda for responsible AI innovation | JD Supra
On October 30, 2023, the Biden Administration issued the groundbreaking Executive Order 14110 on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence1 (Order), which sets in motion a comprehensive US strategy for the responsible development and use of artificial intelligence (AI). The Order goes beyond prior Administration actions on AI in numerous respects.
Updata: Your quarterly privacy & cybersecurity update - July - September 2023 | JD Supra
November 7, 2023 Michael Bahar, Soroosh Faegh, E. Patrick Gilman, Pooja Kohli, Rachel May, Sarah Paul, Rachel Reid, Alexander Sand, Tanvi Shah, Brandi Taylor, Rebekah Whittington, Mary Jane Wilson-Bilik Eversheds Sutherland (US) LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team.
FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing | JD Supra
On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM)1 taking aim at convertible virtual currency (CVC) mixing transactions, utilizing for the first time its power under the Patriot Act to implement a “special measure” for financial institutions for matters related to a “primary money laundering concern”2 (Proposed Rule).
New Legislative Proposals For Outbound US Investment
Background Global events in the last two years have been anything but ordinary. The world succumbed to the global COVID-19 pandemic, the trade war between the United States and China does not appear to be relaxing, and Russia invaded the Ukraine. These events, collectively, have shifted certain tendencies of the United States government both domestically and abroad.
US, UK, And EU Sanctions On Russia Update
What's changed over the past three weeks (since the original alert was published)?
US, UK, And EU Impose Further Sanctions On Russia
To print this article, all you need is to be registered or login on Mondaq.com. Key Takeaways as of 28 February 2022 As the situation regarding the Russian incursion into Ukraine continues to escalate on a day-to-day and hour-to-hour basis, the U.S., U.K., and EU have taken the lead in imposing broad new economic sanctions targeting core aspects of the Russian economy and financial system.
Tokenization: The Revolution Is Now
I. OVERVIEW The future is here. The ideas of tomorrow are happening today. Practical applications for Digital Ledger Technology ("DLT" or blockchain) are not merely notional exercises by anti-establishment, disenfranchised free thinkers. No, the revolution is now. The movement is happening, and investors, corporations large and small, and industry are jumping on board every day.
Traditional Questions Recontextualized
To print this article, all you need is to be registered or login on Mondaq.com. Non-Fungible Tokens (NFTs) are the latest trend in the digital ledger technology space and present tremendous economic potential. While the intersection of NFT technology and the growing number of diverse industries utilizing NFTs is an exciting space to navigate, NFTs and their applications are relatively immature.
Mangrove ecosystems under climate change
Mangrove ecosystems under climate change By: T.C. Jennerjahn , E. Gilman , Ken W. Krauss , L.D. Lacerda , I. Nordhaus , and E.
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