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Defense Production Act FAQs (COVID-19)

  • March 24, 2020
What Authority Does the President Have Under the Defense Production Act to Procure Personal Protective Equipment and Ventilators? The DPA vests the President with “priorities and allocations” authorities to procure and prioritize for the government materials, services, and production where “necessary or appropriate to promote the national defense.
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OFAC Jurisdiction Over US-Origin Technology: SITA Enforcement

  • February 28, 2020
OFAC's sanctions enforcement against SITA, the Switzerland-based provider of global air transport technology and services, premised U.S. sanctions jurisdiction on the provision of U.S.-origin technology and the involvement in transactions of networking hardware and servers located in the United States.
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U.S. Sanctions on Nord Stream 2 and TurkStream Pipeline Projects (NDAA 2020): Legal Analysis

  • December 22, 2019
On December 20, 2019, the President signed into law the National Defense Authorization Act for Fiscal Year 2020 (NDAA), which authorizes the President to impose sanctions on foreign persons that knowingly sell, lease, or provide vessels for the construction of the Nord Stream 2 or TurkStream pipeline projects. The policies advanced by the NDAA are consistent with prior U.S. policy and legislation, particularly the Countering America’s Adversaries Through Sanctions Act. This MassPoint publication discusses PEESA’s policies, sanctions mechanics, the relationship between PEESA and CAATSA, and key takeaways.
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OFAC Cosco Shipping Tanker (Dalian) Co., Ltd. General License K: Analysis

  • October 24, 2019
General License K authorizes, until 12:01 eastern time on December 20, 2019 (essentially, through the end of December 19 eastern time), the above-listed prohibited transactions where they directly or indirectly involve Cosco or entities owned 50% by Cosco and are “ordinarily incident and necessary to the maintenance or wind down of transactions.”
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U.S. Sanctions Chinese Shipping Companies: Legal and Practical Points

  • September 29, 2019
The imposition of sanctions on the Chinese companies and executives—particularly on units of the high-profile, state-owned COSCO at a critical juncture in the U.S.-China trade war and shortly after both countries took conciliatory steps—reinforces the Trump Administration’s stated posture of aggressively enforcing Iran secondary sanctions in furtherance of its policy objectives.
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Foreign Agents Registration Act Enforcement

  • September 20, 2019
MassPoint Legal and Strategy Advisory's Hdeel Abdelhady spoke about FARA enforcement mechanisms, recent and historical enforcement, recent developments and their implications, and questions that might arise in the near future. Ms. Abdelhady's presentation materials are provided here as a resource.
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