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Alison J. Stafford Powell

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On January 27, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. OFAC concurrently published frequently asked questions (FAQs) 878 and 879, which clarify OFAC’s previous guidance on subsidiary entities with names that “closely match”…

On January 12, 2021, the Department of Commerce issued a final rule (the “Final Rule”) amending the Export Administration Regulations (EAR) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (UAS), also known as “drones.” Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum airspeeds of less than 800 km…

On December 22, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) formally added the Central Bank of Syria (“CBOS”) to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) along with certain high-ranking officials in the Syrian government and affiliated entities. Concurrent with OFAC’s designations, the US State Department (State Department) designated six Syrian individuals pursuant to Section 2 of Executive Order 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation…

On November 12, 2020, President Trump signed Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “China Securities EO”), which aims to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases of securities of certain “Communist Chinese military companies.” This development builds on US Government concerns over China’s civil/military fusion and access to US capital markets and financing.…

On August 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (DOT) suspend private charter flights to all Cuban airports. This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized public charter flights to and from Havana and other private charter flights authorized for limited purposes. Secretary Pompeo’s statement cites the Administration’s intent to deny economic resources to…

The US Administration has taken a series of actions in recent days to tighten US export controls for Hong Kong and to sanction Chinese government officials in response to the decision of the Chinese Communist Party (CCP) to impose a new national security law for Hong Kong. Most significantly, these actions put Hong Kong on a par with China with respect to license exception eligibility under the US Export Administration Regulations (EAR) by suspending all EAR…

On May 29, 2020, the president announced in a White House press conference the Administration’s determination that Hong Kong is no longer sufficiently autonomous from the People’s Republic of China (“PRC”), and that the US Government would take “strong and meaningful” steps to “begin the process” of reviewing and revoking the “full range of agreements” that currently provide Hong Kong with preferential treatment. This determination follows Secretary of State Michael Pompeo’s certification to Congress on May 27, 2020 that…

We are pleased to announce the launch of Baker McKenzie’s COVID-19 Product Import/Export Review (“COVID-19 PIER”) tool. This tool is a multijurisdictional tracker that provides information on import and export measures imposed around the world in response to the COVID-19 pandemic. New jurisdictions will be added as we continuously update the information in the tool. The past few months have seen an exponential increase in the demand for personal protective equipment (“PPE”), medical supplies, and other…