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Andrea Tovar

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On January 11, 2021, the US State Department published a press release announcing Cuba’s designation as a State Sponsor of Terrorism (“SST”) for allegedly providing support for acts of international terrorism in granting safe harbor to terrorists. Cuba was originally designated as an SST in 1982 but was delisted in 2015 by President Barack Obama. Cuba’s SST designation follows increasingly stringent sanctions imposed by the US Government including restriction on remittances to Cuba and further restrictions on…

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 December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”).  This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period. The federal register notice regarding the rescission is available here. As detailed in our previous blog post here, the US Government revoked Sudan sanctions in October 2017, but Sudan’s…

On November 17, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule (“Final Rule”) amending and clarifying certain provisions of the Export Administration Regulations (EAR) to make them consistent with the Export Control Reform Act of 2018 (ECRA). The Final Rule also amends certain provisions of the EAR (not strictly concerning ECRA implementation) regarding the issuance of export licenses and denial orders and the payment of civil penalties. For more…

On October 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published a final rule amending the Cuban Assets Control Regulations (CACR) restricting certain remittance-related transactions to and from Cuba (the “Final Rule”). OFAC also published updated and new Frequently Asked Questions (FAQs) related to transactions with Cuba. Significantly, the recent amendments will have the practical effect of making remittances to Cuba more difficult. The Final Rule becomes effective on November 26, 2020 and is…

On August 10, 2020, the Federal Emergency Management Agency (FEMA) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (PPE Products) used in the response to the COVID-19 pandemic (“Extension Rule”). The original restrictions on exports of PPE Products imposed by FEMA were published on April 10, 2020. The Extension Rule became effective August 10, 2020, and will be in…

On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (PRC) and foreign financial institutions who engage in significant transactions with such foreign persons. During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed an Executive…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020 (when published in the Federal Register), to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive…