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Daniel Andreeff

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On June 1, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published the Burma Sanctions Regulations at 31 C.F.R. Part 525 (the “BSR”) to implement Executive Order 14014, “Blocking Property With Respect to the Situation in Burma” (“EO 14014”). EO 14014 imposed sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government. The BSR do not expand upon the sanctions previously imposed under EO 14014, but…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (SDNs), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On April 1, 2021, President Biden signed Executive Order 14022, revoking Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The…

The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (MEC) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (MEHL), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant impact on business activities in Burma as these conglomerates have substantial interests and joint ventures in several sectors of the Burmese economy, including trading, natural…

On February 24, 2021, President Biden signed Executive Order 14017 on America’s Supply Chains (the “Supply Chain EO”) ordering federal agencies to identify vulnerabilities in key US supply chains and develop policy recommendations to make those supply chains more resilient, diverse, and secure. In his remarks prior to signing the Supply Chain EO, President Biden presented the review as a strategic initiative that will complement shorter-term efforts to address recent shortfalls in semiconductor supplies, and one that…

On February 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) removed Ansarallah, a political movement and militia group in Yemen also known as the Houthis, from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Ansarallah had been added to the SDN List on January 19, 2021, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”). As a result of the removal, US Persons no longer require authorization from…

On January 19, 2021, the US State Department designated Ansarallah, a political movement and militia group in Yemen also known as the Houthis, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”), and also designated three of its leaders as SDGTs. OFAC designated Ansarallah on the Specially Designated Nationals and Blocked Persons List (“SDN List”) and updated the entries for the same individuals on the SDN List who had already been designated under other…

On January 5, 2021, President Trump issued Executive Order 13971 “Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies” (“EO 13971”), which targets certain Chinese connected software applications. Specifically, EO 13971 prohibits transactions by any person, or with respect to any property, subject to the jurisdiction of the United States, with persons that develop or control the following Chinese connected software applications, or with their subsidiaries: Alipay, CamScanner, QQ Wallet, SHAREit,…

During the first two weeks in January, the Office of Foreign Assets Control (OFAC) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed 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.” Our prior blog…

On December 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register adding 77 entities and individuals to the Entity List, including several prominent Chinese multinationals (together, the “Designees”). The Final Rule took effect on December 18, 2020. On the same day, BIS also published FAQs related to its recent expansion of the foreign-produced direct product rule (the “Huawei FPDP Rule”). Entity List Designations In press statements (here and here) released with the…