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Trade Sanctions

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On January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”) was enacted into law after the US Congress voted to override the President’s veto of the bill. The defense budget legislation authorizes $740.5 billion for national defense spending and sets policies on military compensation, procurement of equipment, operations, and training. In addition, similar to most National Defense Authorization Acts in recent years, the NDAA 2021 includes provisions regarding sanctions and export…

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 12 January 2021, UK Foreign Secretary Dominic Raab announced new measures to ensure that UK companies are neither complicit in, nor profit from, alleged human rights violations in Xinjiang, China. See press release here. Under the new measures, the UK will review export controls in order to prevent exports of goods potentially contributing, either directly or indirectly, to alleged human rights abuses in Xinjiang. This review will determine specific items that will become subject to…

On January 15, 2021, the Department of Defense (DoD) published in the Federal Register a final rule [Docket DARS–2019–0063] adopting as final, with changes, an interim rule amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement sections of the National Defense Authorization Acts for Fiscal Years 2018 and 2019 related to the procurement of covered telecommunications equipment or services. Specifically, the rule prohibits the use of telecommunications equipment or services from certain Chinese entities…

On January 12, 2021, Global Affairs Canada announced that the Hon. François-Philippe Champagne, Minister of Foreign Affairs, and the Hon. Mary Ng, Minister of Small Business, Export Promotion, and International Trade announced measures related to the human rights situation in the Xinjiang Uyghur Autonomous Region. Canada is gravely concerned with evidence and reports of human rights violations in the People’s Republic of China involving members of the Uyghur ethnic minority and other minorities within the…

On 10 January 2021, the Ministry of Commerce of the People’s Republic of China (“MOFCOM”) promulgated the Rules on Counteracting Unjustified Extra-territorial Application of Foreign Legislation and Other Measures (the “Blocking Rules”), which came into effect the same day. The Blocking Rules were formulated in accordance with the PRC National Security Law, and aim to (amongst others) counteract the impact on Chinese companies and citizens caused by unjustified extra-territorial application of foreign legislation and other relevant measures…

On January 11, 2021, the US State Department published a press release announcing Cuba’s designation as a State Sponsor of Terrorism (“SST”) for allegedly providing support for acts of international terrorism in granting safe harbor to terrorists. Cuba was originally designated as an SST in 1982 but was delisted in 2015 by President Barack Obama. Cuba’s SST designation follows increasingly stringent sanctions imposed by the US Government including restriction on remittances to Cuba and further restrictions on…

On January 8, 2021 the Department of State published in the Federal Register an update [Public Notice 11296] to its List of Restricted Entities and Subentities Associated With Cuba (Cuba Restricted List) with which direct financial transactions are generally prohibited under the Cuban Assets Control Regulations (CACR). The Department of Commerce’s Bureau of Industry and Security (BIS) generally will deny applications to export or reexport items for use by entities or subentities on the Cuba…

On December 22, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) formally added the Central Bank of Syria (“CBOS”) to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) along with certain high-ranking officials in the Syrian government and affiliated entities. Concurrent with OFAC’s designations, the US State Department (State Department) designated six Syrian individuals pursuant to Section 2 of Executive Order 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation…

          January 2021         GCC and Egypt sign the “Al-Ula Declaration”, ending the Qatar boycott                  On 5 January 2021, the Kingdom of Saudi Arabia, the United Arab Emirates (UAE), Bahrain and the rest of the Gulf Cooperation Council (GCC) member states, along with Egypt, signed the “Al-Ula Declaration” at the 41st GCC Summit held in the city of Al-Ula, paving the way…