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Kerry B. Contini

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On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy. In connection with its establishment of full diplomatic ties with Israel last year under the UAE-Israel Abraham Accords,…

The US Treasury Department’s Office of Foreign Assets Control (OFAC), the US State Department (State), and the US Commerce Department (Commerce) issued rules adjusting maximum civil monetary penalties (CMPs) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (FCA), as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule published on March 17, 2021, the adjusted penalties apply to CMPs that are assessed…

On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) strengthened restrictions targeting Burma by adding Burma to the list of countries subject to the Export Administration Regulations’ (EAR’s) military-intelligence end-use and end-user controls and controls on certain support activities by US persons (“Interim Final Rule“). These controls were first issued on January 15, 2021 (“January Rule“), and became effective March 16, 2021.  Our blog posts on other recent sanctions targeting Burma…

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…

Baker McKenzie’s Global Supply Chain Compliance Blog recently published a post entitled, “UK, US and Canadian Governments Announce New Measures Over Alleged Xinjiang, China Human Rights Concerns”.  The new blog post can be found here.  The post outlines recent measures introduced by the governments of the United Kingdom, the United States, and Canada in response to the alleged human rights violations taking place in Xinjian, China.  The new measures implemented by these governments include enhanced due diligence requirements…

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 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”) was enacted into law after the US Congress voted to override the President’s veto of the bill. The defense budget legislation authorizes $740.5 billion for national defense spending and sets policies on military compensation, procurement of equipment, operations, and training. In addition, similar to most National Defense Authorization Acts in recent years, the NDAA 2021 includes provisions regarding sanctions and export…

On October 26, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated additional Iranian individuals, entities and vessels to the Specifically Designated Nationals and Blocked Persons List (the “SDN” List) pursuant to Executive Order 13224 (as amended) (EO 13224), a counter-terrorism authority, for their support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), an entity designated under EO 13224. Among the designated entities are the Iranian Ministry of Petroleum, the National Iranian Oil…

On September 21, 2020, the Federal Emergency Management Agency (FEMA) pushed back the submission deadline for comments related to the letter of attestation process for exports of certain personal protection equipment (PPE). FEMA published the request for comments in July 2020 but reportedly did not receive any. The export restrictions and letter of attestation process was created earlier this year in response to potential shortages of certain kinds of PPE as a result of the…

On July 31, 2020, the Department of Commerce Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to suspend the availability of all License Exceptions for Hong Kong that provide differential treatment relative to mainland China. Our blog post on prior steps taken to revoke preferential treatment for Hong Kong, including the initial announcement of these suspensions, is available here. The following partial or full License Exceptions are no longer available for exports…