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Janet K. Kim

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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…

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…

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…

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…

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…