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U.S. Imposes Targeted Sanctions And Export Restrictions On Burma In Response To Military Coup

On February 1, 2021, the military of Burma (Myanmar) in an unanticipated coup d’état installed General Min Aung Hlaing as leader and detained the country’s top elected leaders, including the President and Prime Minister. In...more

OFAC Implements Hong Kong-Related Sanctions Regulations Pursuant To E.O. 13936

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published regulations in the Federal Register on January 15, 2021 to implement Executive Order 13936 (“E.O. 13936”), titled “The President’s...more

Commerce Publishes Interim Final Rule Addressing “Foreign Adversaries” In ICTS Supply Chain

On January 19, 2021, the U.S. Department of Commerce (Commerce) published a long-awaited interim final rule to address the use of goods or services sourced from “foreign adversaries” in the U.S. supply chain for information...more

Commerce Department Publishes Interim Final ICTS "Foreign Adversary" Rules

Key Point: New rules will impact the use of equipment and digital services sourced from China and other “foreign adversaries” in a wide variety of transactions and activities that potentially pose a risk to U.S. national...more

BIS Amends EAR To Implement Rescission Of Sudan’s State Sponsor Of Terrorism Designation

On January 14, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it has amended the Export Administration Regulations (“EAR”) to formally implement the rescission of Sudan’s...more

USTR Extends Section 301 Exclusions For Certain Medical Equipment

The Office of the United States Trade Representative (“USTR”) announced that it is extending certain product-specific exclusions related to the treatment of COVID-19 from the Section 301 tariffs on imports from China until...more

GSP Special Tariff Status To Expire At End Of 2020

U.S. Customs and Border Protection (“CBP”) issued a notice announcing the lapse of the Generalized System of Preferences (“GSP”) special tariff program, effective December 31, 2020, unless renewed by an act of Congress. The...more

BIS Adds Over 70 New Entities To The Entity List, Including SMIC

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule amending the Export Administration Regulations (“EAR”) to add 77 entities to the Entity List. This rule took effect on Friday,...more

U.S. Sanctions Turkey’s Defense Procurement Entity Over Its Purchase Of Russian Missile System

The U.S. Department of State (“State Department”) announced the imposition of sanctions on Turkey’s Presidency of Defense Industries (“SSB”) pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions...more

Sudan’s Sponsor Of Terrorism Designation Officially Rescinded

The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation...more

OFAC Sanctions CEIEC For Its Support To Venezuela Regime

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned CEIEC (China National Electronic Import-Export Company), a Chinese technology exporter, for its alleged support to the Maduro government...more

BIS Amends EAR To Implement Export Enforcement Provisions Of Export Control Reform Act

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a final rule, effective November 18, 2020, which revises certain provisions of the Export Administration Regulations (“EAR”) to...more

OFAC Issues Venezuela General License 8G Extending Authorization Of Certain Transactions For U.S. Oil & Gas Companies

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 8G (“GL 8G”), which authorizes five (5) U.S. oil and gas companies to engage in transactions “ordinarily incident and...more

Executive Order Prohibits U.S. Persons From Investing In “Communist Chinese Military Companies”

President Trump issued an Executive Order (“E.O.”) on November 12, 2020 titled “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.” The E.O., which will be published in the...more

BIS Amends License Review Policy For National Security Controlled Items Destined For China, Venezuela, And Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule effective October 29, 2020 amending Section 742.4(b)(7) of the Export Administration Regulations (“EAR”) to revise the license...more

White House Rescinds Sudan’s State Sponsor Of Terrorism Designation, Continues National Emergency

On November 2, 2020, the White House released a notice continuing the national emergency with respect to Sudan declared in Executive Order 13067 of 1997. Secretary of State Mike Pompeo issued a press statement clarifying...more

U.S. Moves To Block Conventional Arms Sales To Iran

President Trump issued an Executive Order on September 21, 2020 which, effective immediately, imposes secondary sanctions on the transfer and sale of certain conventional arms shipments and the supply of related services to...more

U.S. Scheduled Bans On TikTok And WeChat Apps Delayed

China-based smartphone apps, TikTok and WeChat, have each received a reprieve from the respective bans, which were originally ordered by President Trump on August 6, 2020 against both parties and were scheduled to take effect...more

D.C. Federal Judge Rules EAR Does Not Infringe FedEx’s Rights

A federal judge for the U.S. District Court for the District of Columbia dismissed FedEx Corporation’s challenge to the U.S. Department of Commerce’s (Commerce) Export Administration Regulations (EAR). Specifically, FedEx...more

BIS Seeks Comments On Identifying “Foundational Technologies”

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently published an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding the identification and review of controls for certain “foundational...more

Updated CBP Marking Guidance On Goods From Hong Kong; Effective Date Pushed Back To November 9, 2020

On August 10, 2020, U.S. Customs and Border Protection (CBP) issued a notice announcing that goods produced in Hong Kong and exported to the U.S. must now be marked as a product of China (e.g., Made in China). The marking...more

U.S. Seeks Snapback Of U.N. Sanctions On Iran Despite Departure From Nuclear Deal

The United States is formally demanding that the United Nations (U.N.) reimpose sanctions on Iran for its failure to meet commitments to limit its nuclear program set forth under the Joint Comprehensive Plan of Action...more

U.S. Adds 38 New Huawei Affiliates To Entity List While Again Expanding Foreign-Produced Direct Product Rule

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has announced that it is further restricting access by Huawei Technologies Co. Ltd. and its designated non-U.S. affiliates (“Huawei”) to U.S.-produced...more

U.S. Moves To Ban TikTok And WeChat Apps Amid U.S.-China Tensions

On August 6, 2020, the White House issued two (2) Executive Orders (“EO”) banning the popular China-based social media app TikTok and the messaging and electronic payments app WeChat. Both orders are scheduled to take effect...more

U.S. Increases Pressure On Russian Gas Pipelines with Imposition Of New CAATSA Secondary Sanctions; Issues New General Licenses...

The U.S. Department of State recently published updated guidance pertaining to Section 232 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The revised guidelines subject energy export pipelines...more

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