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Ryan Poitras

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US – Commerce removes Hong Kong as a separate designation under the EAR

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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…

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 – BIS adds 24 Chinese Companies to the Entity List for their activities in the South China Sea

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On August 27, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule (“Final Rule”) adding 24 Chinese state-owned entities to the Entity List (the “SCS Designees”), including several subsidiaries of China Communications Construction Company (CCCC), due to their ties to land reclamation efforts involving artificial islands in the South China Sea. In a press statement released with the designations, the Commerce Department cited the role played by the SCS Designees in building and militarizing…

US – Trump Administration approves updated unmanned aerial system export policy

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On July 24, 2020, the Trump Administration announced a new policy (the “Updated UAS Policy”) on exports of US-origin unmanned aerial systems (UAS), also known as “drones.” The Updated UAS Policy follows the Trump Administration’s UAS policy reforms announced in April 2018 (“April 2018 UAS Export Policy”), which allowed exports of certain US-origin armed and unarmed UAS to occur via direct sales between US companies and foreign end users. Our previous blog post on the April 2018 UAS…

US – OFAC releases FAQs providing guidance on the Iran Sectoral Sanctions in Executive Order 13902

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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,…