Meghan Hamilton – International Trade Compliance Update

US Government imposes sanctions on the Iranian financial sector under Executive Order 13902 and designates 18 Iranian banks

October 15, 2020 by Janet K. Kim, Meghan Hamilton and Ryan Poitras 4 Mins Read

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…

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

August 12, 2020 by Andrea Tovar, Meghan Hamilton and Kerry B. Contini 2 Mins Read

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…

US Government warns businesses of human rights risks in supply chain in Xinjiang, China

July 17, 2020 by Bart M. McMillan, Meghan Hamilton, Maria Sergeyeva and John Foote 2 Mins Read

On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”) in China…

US Commerce Department authorizes the release of certain technologies to Huawei Listed Entities in standards-development activities

June 25, 2020 by Kerry B. Contini, Meghan Hamilton and Laura Klick 1 Min Read

On June 15, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (“Interim Final Rule”) effective on June 18, 2020 to authorize the limited release of certain items subject to the Export Administration Regulations (EAR) to Huawei and its affiliates listed on the BIS Entity List (“Huawei Listed Entities”) in the context of international efforts to develop technical standards for 5G and other new technologies. In a statement, the Commerce…