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Meghan Hamilton

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US – BIS amends Country Groups for Ukraine, Mexico, and Cyprus under the EAR

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On December 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to revise the Country Group designations for Ukraine, Mexico, and Cyprus. BIS has placed these countries’ into more permissive Country Groups due to these countries’ membership in multilateral export control regimes, as well as national security interests and policies compatible with those of the United States. The impact of these changes is…

US Government removes Sudan from State Sponsor of Terrorism list

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On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”).  This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period. The federal register notice regarding the rescission is available here. As detailed in our previous blog post here, the US Government revoked Sudan sanctions in October 2017, but Sudan’s…

US – OFAC extends Venezuela-related General License authorizing wind-down transactions

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On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (OFAC) amended General License (“GL”) 8F and re-issued it as General License 8G. GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021. Our blog posts describing previous amendments to the general license are available here, here, here, and here. Specifically, GL 8G extends the validity period…

President signs Executive Order prohibiting US Persons from purchasing securities of certain Chinese companies

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On November 12, 2020, President Trump signed Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “China Securities EO”), which aims 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.” This development builds on US Government concerns over China’s civil/military fusion and access to US capital markets and financing.…

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

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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

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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…

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

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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

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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…