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Kerry B. Contini

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US – Annual increase in civil monetary penalties for US Treasury, State, and Commerce Departments

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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…

Commerce extends military-intelligence end-use and end user controls to Burma

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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…

US – President Biden signs Executive Order to review and strengthen US supply chains

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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…

UK, US and Canadian Governments announce new measures over alleged Xinjiang, China human rights concerns

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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…

Trump Administration designates Ansarallah and issues humanitarian general licenses; Biden Administration issues general license temporarily authorizing most Ansarallah transactions

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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…

US enacts NDAA 2021 with additional sanctions against Turkey, Russia, and China

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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…

US – OFAC designates additional Iranian persons; issues General License 8A to cover humanitarian transactions involving NIOC

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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…

US – FEMA extends comment submission period on Letter of Attestation Process for PPE export restrictions

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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…

US – Commerce suspends license exceptions for Hong Kong that provide differential treatment relative to China

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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…

US – FEMA extends duration of restrictions on exports of PPE and modifies products covered

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On August 10, 2020, the Federal Emergency Management Agency (FEMA) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (PPE Products) used in the response to the COVID-19 pandemic (“Extension Rule”). The original restrictions on exports of PPE Products imposed by FEMA were published on April 10, 2020. The Extension Rule became effective August 10, 2020, and will be in…