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Lise S. Test

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On July 14, 2020, President Trump issued Executive Order 13936 on Hong Kong Normalization (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong to be treated the same as mainland China. It also authorizes sanctions against persons involved in developing, adopting, or implementing China’s Law on Safeguarding National Security in the Hong…

On June 5, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published four Frequently Asked Questions (FAQs) regarding Iran-related sanctions under Executive Order 13902 (EO 13902). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs reconfirm that Iranian manufacturers of medicines,…