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Eunkyung Kim Shin

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On September 1, 2020, the US Department of State’s Bureau of International Security and Nonproliferation, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Department of Commerce’s Bureau of Industry and Security issued a joint advisory on North Korea’s ballistic missile procurement activities (“Advisory”). The Advisory, among other things, identifies key participants of North Korea’s ballistic missile procurement and their deceptive tactics and key items, including materials and equipment, used…

On August 17, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule (published in the Federal Register on August 20, 2020) (i) expanding the Export Administration Regulations (EAR) General Prohibition Three (the foreign-produced direct product rule, or the “FPDP Rule”) to further restrict Huawei Technologies Co. Ltd. and its affiliates designated on the BIS Entity List (collectively, “Huawei”) from acquiring foreign-produced semiconductors that are the direct product of certain US…

On July 15, 2020, the US Department of State (State Department) updated its guidance (“Updated Guidance“) regarding the implementation of Section 232 of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here and our previous blog post on the 2017 State Department guidance on CAATSA Section 232 here). The Updated Guidance expands the scope of CAATSA Section 232 to target certain investments or other activities related to the Nord Stream…

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 June 11, 2020, President Trump issued Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (“ICC EO“), which authorizes the imposition of sanctions and visa restrictions on non-US ICC officials in connection with investigations into US or allied government officials or military personnel. The United States is not a party to the Rome Statute, which is the treaty that established the ICC. The President declared a national emergency under…