Author

Lise S. Test

Browsing

On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, effective June 8, amending the Export Administration Regulations (EAR) to reflect the formal termination by the United Arab Emirates (UAE) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after August…

On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued three pandemic-related general licenses (“GLs“) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19 (including research or…

On May 18, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 1B, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1B”) in relation to OFAC’s Communist Chinese Military Companies (CCMCs) sanctions program as implemented pursuant to Executive Order 13959 (EO 13959) and amended by Executive Order 13974. Our blog posts on EO 13959 and OFAC’s prior guidance on the CCMC sanctions program are available here and here. As with the original…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (SDNs), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On April 1, 2021, President Biden signed Executive Order 14022, revoking Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The…

On March 18, 2021, the US State Department (State) published a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by State and were summarized…

On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to remove Sudan’s designation as a State Sponsor of Terrorism (SST) (the “Amendments”). The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing Anti-Terrorism (AT) and related controls on Sudan, which had remained in force following the US Government’s revocation of comprehensive sanctions in October 2017. …

On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (EO 14014), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance of EO 14014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated thirteen parties on February 10, 2021 and two parties on February 22, 2021 connected…

On January 5, 2021, President Trump issued Executive Order 13971 “Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies” (“EO 13971”), which targets certain Chinese connected software applications. Specifically, EO 13971 prohibits transactions by any person, or with respect to any property, subject to the jurisdiction of the United States, with persons that develop or control the following Chinese connected software applications, or with their subsidiaries: Alipay, CamScanner, QQ Wallet, SHAREit,…

During the first two weeks in January, the Office of Foreign Assets Control (OFAC) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases of securities of certain “Communist Chinese military companies.” Our prior blog…