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On November 12, 2015, President Barack Obama issued Executive Order 13710 (here) ending sanctions related to the Republic of Liberia (“Liberia”) originally put in place in 2004 under Executive Order 13348 (here). Executive Order 13710 cited Liberia’s recent democratic progress as the main reason for lifting sanctions. Parties that were designated as specially designated nationals (“SDNs”) under Executive Order 13348 are no longer SDNs. On November 23, 2015, President Obama issued an Executive Order (“Order”) (here) imposing sanctions related to the Republic of Burundi (“Burundi”) primarily due to “the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression” occurring in Burundi. The imposition of U.S. sanctions follows the European Union (“EU”) Council decision made on October 2, 2015, which designated four Burundi individuals as designated parties. See our blog post on this action here. Four individuals were designated as SDNs under the Order: (i) Alain Guillaume Bunyoni, Minister of Public Security; (ii) Godefroid Bizimana, Deputy Director-General of the National Police (also an EU designated party); (iii) Godefroid Niyombare, Major General, Former Chief of Burundi Intelligence Service; and (iv) Cyrille Ndayirukiye, Former Minister of Defense. Among other things, the Order targets those determined by the Secretary of the Treasury, in consultation with the Secretary of State, to be responsible for or complicit in, or to have engaged in, directly or indirectly: (i) actions or policies that threaten the peace, security, or stability of Burundi or (ii) actions or polices that undermine democratic processes or institutions in Burundi. The order also authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to target any person owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, any person whose property or interests in property are blocked pursuant to the order. Parties designated or identified under the Order will have their property and interests in property in the United States blocked or frozen, and U.S. persons are prohibited from dealing with them and any entities owned, directly or indirectly, 50% or more by one or more of the SDNs. The Order also imposes visa restrictions on individuals designated or identified under the Order.


Paul Amberg is a partner in Baker McKenzie’s Amsterdam office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters.


Eunkyung Kim Shin is an associate of Baker McKenzie’s International Commercial Practice Group and the International Trade Compliance Sub-Practice Group in the Chicago office. Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws.

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