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Terence Gilroy

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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…

The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (MEC) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (MEHL), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant impact on business activities in Burma as these conglomerates have substantial interests and joint ventures in several sectors of the Burmese economy, including trading, natural…

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. …

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…

On October 9, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the comment period for the advance notice of proposed rulemaking (ANPRM) on criteria of “foundational technologies.” Comments may now be submitted through November 9, 2020; two weeks after the original deadline of October 26. BIS also clarified it will accept confidential business information from commenters. Filers submitting confidential information should clearly identify the confidential portion at the time of the submission and must…

On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (PRC) and foreign financial institutions who engage in significant transactions with such foreign persons. During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed an Executive…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020 (when published in the Federal Register), to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive…