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Paul Amberg

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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,…

On December 23, 2020, the Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR), in further implementation of Executive Order 13936 (EO 13936), to remove provisions that provide differential and preferential treatment for exports, reexports, and transfers of items to Hong Kong as compared to China. As a result of these changes, Hong Kong will be removed as a separate destination on the Commerce Country Chart and in other places in the EAR, which…

On November 17, 2020, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule (“Final Rule”) amending and clarifying certain provisions of the Export Administration Regulations (EAR) to make them consistent with the Export Control Reform Act of 2018 (ECRA). The Final Rule also amends certain provisions of the EAR (not strictly concerning ECRA implementation) regarding the issuance of export licenses and denial orders and the payment of civil penalties. For more…

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This article highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…