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Janet K. Kim

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Commerce solicits public comments on licensing procedures for Information and Communications Technology and Services Supply Chain transactions

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On March 29, 2021, the Commerce Department published an advance notice of proposed rulemaking (ANPRM) seeking public comment on potential licensing or other pre-clearance processes for transactions under the regulations that took effect on March 22, 2021 to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (Executive Order 13873). Executive Order 13873 authorizes the Commerce Department to block or impose conditions on transactions involving information and communications technology and services (ICTS) originating in countries…

US – Biden Administration removes Ansarallah from the SDN List and revokes its designation as a Foreign Terrorist Organization

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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…

US – FEMA modifies and extends export restrictions for PPE and other medical products

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On December 31, 2020, the Federal Emergency Management Agency (FEMA) issued a temporary final rule extending and modifying export restrictions on certain types of medical supplies and personal protection equipment products (“PPE Products“) used in response to the COVID-19 global health pandemic. The new rule became effective December 31, 2020; extends previously-imposed export restrictions on covered PPE Products to June 30, 2021; and adds certain types of syringes and needles to the list of covered PPE Products. We…

US – Four additional Chinese entities subject to restriction on US securities transactions

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On December 3, 2020, the Department of Defense announced its third list of “Communist Chinese military companies” operating in the United States, pursuant to Section 1237 of the National Defense Authorization Act for Fiscal Year 1999, as amended (“Section 1237”). The practical impact of the announcement is that these four companies become subject to Executive Order 13959, which restricts US investment in these companies. The first and second lists also issued pursuant to Section 1237 are found here and here. The…

US Government imposes sanctions on the Iranian financial sector under Executive Order 13902 and designates 18 Iranian banks

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On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) identified the Iranian financial sector as subject to Executive Order (EO) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many humanitarian transactions and activities will…

US – BIS adds 24 Chinese Companies to the Entity List for their activities in the South China Sea

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On August 27, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule (“Final Rule”) adding 24 Chinese state-owned entities to the Entity List (the “SCS Designees”), including several subsidiaries of China Communications Construction Company (CCCC), due to their ties to land reclamation efforts involving artificial islands in the South China Sea. In a press statement released with the designations, the Commerce Department cited the role played by the SCS Designees in building and militarizing…

Trump Administration authorizes sanctions targeting International Criminal Court officials

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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…