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The Trump Treasury announced key senior appointments, assigning Secretary Scott Bessent a management team with proven loyalties to the President.      John Hurley is nominee to serve as Under Secretary for Terrorism and Financial Intelligence.  Mr. Hurley is currently the Managing Partner of Cavalry Asset Management and Managing Member of TGK Ventures.  From 2018-2021, Mr. Hurley served on President Trump’s Intelligence Advisory Board. The now relieved Acting Under Secretary for Terrorism and Financial Intelligence is Bradley Smith , a career Treasury official who had held the role since August 2024.  Previously, Mr. Smith  served as the Director and Deputy Director of OFAC, playing a pivotal role in implementing sanctions, notably those targeting Russia following its 2022 invasion of Ukraine. With the recent ousting of Matt Borman as Principal Deputy Assistant Secretary for Export Administration at the Commerce Department's Bureau of Industry and Security (BIS), the sanctions community is waiting with bated breath to see what happens to Mr. Smith.

In contrast to the Treasury Department's flurry of staffing announcements, the Commerce Department quietly updated its website this week, detailing the staff incoming BIS Chief Jeffrey Kessler will rely on to ensure trade security. The appointment of James Rokas as Mr. Kessler's principal deputy has been thrown into doubt, as Chief of Staff Robert Burkett has replaced Mr. Rokas as acting undersecretary.

President Trump’s decision to revoke a requirement that recipients of arms transfers respected international laws drew jeers and cheers on Capitol Hill.  National Security Memorandum 20 (NSM-20) was a Biden-era directive designed to enhance oversight of U.S. arms transfers, ensuring they were not misused by foreign partners in ways that violated human rights.

White House trade adviser Peter Navarro has firmly denied reports that he advocated for Canada’s removal from the Five Eyes intelligence-sharing alliance, calling the notion “crazy stuff.” His comments come amid escalating trade and diplomatic tensions between the two neighboring countries. The potential move to exclude Canada from Five Eyes is reportedly being considered as a pressure tactic amid Trump’s intensifying threats to annex Canada

Jeffrey Kessler the Administration's nominee for Under Secretary of Commerce for Industry and Security had a relatively easy go of it in front of the Senate Banking Committee Thursday, as members sunk their teeth into the higher-profile nominees who shared the dias. While Mr. Kessler brings a strong legal background in tariff and trade enforcement and compliance, the technical and national security elements of export administration will call for a high degree of collaboration with what one senator referred to as  "career bureaucrats [who] over the years at BIS have rubber stamped deals for decades and sent some of our most important technology to China"

Alabama man Ray Hunt, has been sentenced to five years in prison for violating the International Emergency Economic Powers Act. In July 2024, Hunt pleaded guilty to conspiring to export U.S.-origin goods to the Islamic Republic of Iran in violation of the U.S. trade sanctions. Beginning at least as early as 2015 and continuing to the time of his arrest in November 2022, Hunt conspired with two Iranian companies located in Tehran, Iran, to illegally export U.S.-manufactured industrial equipment for use in Iran’s oil, gas, and petrochemical industries.

Matthew Borman, principal deputy assistant secretary of commerce for export administration and Eileen Albanese, director of the Office of National Security and Technology Transfer Controls, have been forced out of the Commerce Department, leaving the government's trade security functions hobbled. As reported earlier Bureau of Industry and Security (BIS) has suspended the processing of applications for new export licenses submitted after February 5th, 2025.   As of presstime (24 February) the Bureau has made no formal announcment as to when or if processing will resume.

As Moscow's war against Ukraine enters its fourth (or eleventh) year, the European Commission announced the Council's adoption of the 16th sanctions package against Russia. As is customary, the United Kingdom announced complementary sanctions. Unlike with prior initiatives, the United States did not join in the effort, reflecting the new rapprochement between Washington and the Kremlin. The 16th sanctions package intensifies restrictions on key sectors of Russia's economy, including energy, trade, transport, infrastructure, and financial services.

In 2024, probably for the first time ever, Europe (meaning the EU, UK, Switzerland and Norway), imposed and obtained a greater number of fines and convictions; a higher total value of fines; and also a higher single largest fine, for sanctions breaches than those imposed by the authorities in the United States. A note compiled by Mark Handley of Duane Morris, London, tallies combined enforcement actions taken by OFAC and BIS, as well as criminal convictions secured by the DOJ, as compared to their European peers.

Monday 24 February, Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the StateDepartment, imposed sanctions on more than 30 individuals, entities, and vessels for their roles in facilitating the sale and transportation of Iranian petroleum-related products. This latest round of sanctions includes oil brokers based in the United Arab Emirates (UAE) and Hong Kong, tanker operators in India and the People's Republic of China (PRC), as well as senior officials and subsidiaries of Iran's National Iranian Oil Company (NIOC).

February 21, the President announced an "America First Investment Policy," aimed at promoting foreign investment from allies while restricting investments from adversarial nations, notably the People's Republic of China (PRC).

The Office of the United States Trade Representative (USTR) announced proposed actions in response to China’s alleged targeting of the maritime, logistics, and shipbuilding sectors for global dominance, including the imposition of entry fees on Chinese ships calling at US ports. Subsidies for U.S.-built ships are proposed, targeting a more than tenfold increase in carriage on US-built chips within seven years.

Friday President Trump signed a directive aimed at protecting American companies from foreign-imposed taxes, fines, and regulatory restrictions, vowing to take retaliatory action against governments that unfairly target U.S. businesses. The Presidential Memorandum, titled Defending American Companies and Innovators From Overseas Extortion and Unfair Fines and Penalties, outlines the administration’s commitment to countering digital services taxes (DSTs) and other financial measures that disproportionately affect U.S. technology firms.

The Financial Action Task Force (FATF)—the global standard-setting body for anti-money laundering, countering the financing of terrorism, and proliferation of weapons of mass destruction—concluded a plenary in Paris February 21. During the plenary the FATF discussed ongoing work on evolving proliferation financing and terrorist financing risks, financial inclusion, and standards for domestic and cross-border payments, including agreeing to release draft updates for public consultation. The suspension of the Russian Federation continues to stand.

The United States extended its lead as the top destination for direct investment in 2023, attracting nearly $5.4 trillion of foreign capital according to IMF Data released last week. FDI rose in most regions, with Central and South Asia, Europe, and North and Central America contributing most. Direct investment between advanced economies grew by $880 billion, or 3.6 percent, while those from advanced economies to emerging market and developing economies rose by $538 billion, or 7.6 percent.

Commodity Futures Trading Commission Acting Chairman Caroline D. Pham today announced Brian Young will serve as the agency’s Director of Enforcement. Young has been serving in an acting capacity since January 22, and previously was the Director of the Whistleblower Office. Young joined the CFTC in 2024 as the Director of the Whistleblower Office following nearly 20 years at the Department of Justice.

President Trump intends to nominate John Eisenberg to head the Justice Department's National Security Division. Eisenberg previously served as Legal Advisor to the National Security Council during President Trump’s first term, where he was also Assistant to the President and Deputy Counsel to the President for National Security Affairs. Brett Shumate is tapped as chief of the Civil Division, and Patrick Davis will head the Office of Legislative Affairs. In other national security news, the nomination of Kash Patel as FBI Director has been confirmed by the Senate.   Republican Senators Susan Collins of Maine and Lisa Murkowski of Alaska, joined all Democrats in opposing Patel.

An Israeli national was sentenced Friday to 24 months in prison and three years of supervised release for conspiracy to illegally ship aircraft parts and avionics from U.S. manufacturers and suppliers to Russia, including for the benefit of sanctioned Russian airline companies. In addition, Gail Haimovich paid the full forfeiture amount of $2,024,435.44. Between approximately March 2022 and May 2023, Haimovich facilitated the export of aircraft parts and avionics, including those with missile technology applications, from the United States through the Southern District of Florida, to various third-party transhippers on behalf of Russian customers.

Thursday, OFAC launched its new File Finder application  for use on the OFAC website. The rowser-based application allows users to search through and efficiently navigate all of OFAC's website content.

The Senate Tuesday evening approved the nomination of financier Howard Lutnick as Commerce Secretary, putting in place a key proponent of President Trump’s trade policy. The nomination was approved by a mostly party line vote of 51 to 45.

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