Something Borrowed, Something New; An Update on Recent Treasury and State Department Actions

While much attention has been focused on the Trump Administration's recent actions targeting imports of metals, lumber, and other commodities, the Administration has also steadily ramped up its activities in the trade controls space, by ordering a review of the Iran nuclear deal, targeting a number of Syrian persons with additional sanctions, and staying the course on Russia. While some of these actions, such as the large number of Syrian designations, are intended to signal a break with the Obama Administration, others, such as publicly reconfirming that U.S. companies will not be allowed to engage in certain drilling activities in Russia, have continued existing policies. As with many other areas, the Trump Administration's policy direction is still up in the air, and companies need to ensure that they have plans in place for a variety of different scenarios. We summarize below a number of key actions that could impact businesses.

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