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Enforcement & Investigations

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The recent couple of years have been a compliance roller coaster ride for businesses with supply chains involving China. China went on a major legislative revamp and rolled out a series of new laws, including the new Export Control Law (ECL) of the People’s Republic of China (PRC), which came into force on 1 December 2020. In our past client alerts, we wrote about the status of the implementation of the ECL and the principles…

On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, effective June 8, amending the Export Administration Regulations (EAR) to reflect the formal termination by the United Arab Emirates (UAE) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after August…

Following coordinated designations of certain Belarusian individuals and entities earlier this week (see our previous post here), the EU has announced that further sector-based economic sanctions will come into force on 25 June 2021. The restrictions are implemented by Council Regulation (EU) 2021/1030 (the “Regulation“), which amends Regulation (EC) No 765/2006. The new sanctions target a broad range of technology and software, dual-use goods and technology, tobacco, petroleum and potash products, and financial services. The prohibitions apply regardless of…

On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued three pandemic-related general licenses (“GLs“) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19 (including research or…

Effective June 21, 2021, the Government of Canada imposed new sanctions against 17 individuals and 5 entities under the Special Economic Measures (Belarus) Regulations (the “Regulations”). The sanctions were imposed in response to alleged systemic human rights violations and the May 23, 2021 diversion, by the Belarusian regime, of Ryanair Flight 4978 from its planned course in order to land in Minsk. The imposition of sanctions by the Government of Canada was taken in coordination with the…

On June 24, 2021, the White House announced that US Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) on silica-based products made by Hoshine Silicon Industry Co., Ltd., a company located in Xinjiang, and its subsidiaries. This WRO is based on information reasonably indicating that Hoshine used forced labor to manufacture silica-based products. As a result, personnel at all U.S. ports of entry have been instructed to immediately begin detaining shipments…

On June 23, 2021, the Department of Labor published in the Federal Register a notice announcing public availability of an updated list of goods—along with countries of origin—that the Bureau of International Labor Affairs (ILAB) has reason to believe are produced by child labor or forced labor in violation of international standards (the List). ILAB is required to develop and make available to the public the List pursuant to the Trafficking Victims Protection Reauthorization Act…

On 21 June 2021, the UK and EU both announced further sanctions targeting individuals and entities linked to Myanmar’s military regime. The EU announced that it was imposing sanctions against an additional 8 individuals, 3 economic entities (Myanmar Gems Enterprise; Myanmar Timber Enterprise (“MTE“); and Forest Products Joint Venture Corporation Limited) and the War Veterans Organisation. All designated persons are subject to asset freezes, with individuals subject to travel bans. EU persons are prohibited from making funds…

On 21 June 2021, the EU and UK announced coordinated sanctions against specified Belarusian individuals and entities. This follows the forced landing of a commercial aircraft in Belarus and subsequent detention of a Belarusian journalist, and suggests that the UK is continuing to align its sanctions regime with key allies following Brexit. The sanctions were further coordinated with the US and Canada. The designated parties will be subject to asset freezes, whilst individuals will be subject to…

On 11 June 2021, the Recast Dual-Use Regulation was published in the Official Journal of the European Union as Regulation 2021/821 (the “Regulation”). The Regulation, which comes into force on 9 September 2021, will replace the current Dual-Use Regulation introduced in 2009. Key changes include: Two new general export authorisations: The Regulation introduces a general export authorisation for intra-group transfers of dual use software and technology to specified countries for product development purposes, that is available where…