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Alexandre Lamy

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Alexandre Lamy joined Baker McKenzie in 2009 and currently works in the Firm's International Trade Practice Group. He assists clients with sanctions and export controls (Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR)) and he advises clients on corporate compliance matters. Since August 2011, Alex has served on the steering group for the ABA Section of International Law’s Export Controls & Economic Sanctions Committee and is currently a Vice Chair of the Committee. He has organized several events regarding recent developments in US trade sanctions and export controls for the Committee.

On 19 August 2021, the Federal Communications Commission published a notice of proposed rulemaking discussing potential changes it is considering making to its equipment authorization and competitive bidding programs to restrict the use of telecommunications and video surveillance equipment and services produced or provided by five Chinese companies.

We are pleased to invite you to our annual virtual Global Year-End Review of Import/Export/Trade Compliance Developments. Our international trade compliance lawyers from around the world will review the major global legislative, judicial and administrative activities and trends in export controls, trade sanctions, customs compliance, and import requirements which will be 16-18 November 2021.

On July 19, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding six Russian organizations to the Entity List. These designations are related to Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian” (“EO 14024”) that was signed by President Biden in April 2021.

On January 19, 2021, the US Commerce Department published an interim final rule (“Interim Rule”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services (“ICTS”) Supply Chain.” The Interim Rule was issued following the public comment period’s closure on January 10, 2021 on the proposed rules issued on November 27, 2019.

On June 9, 2021, the Biden Administration issued Executive Order 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (“EO 14034”). EO 14034 revokes three executive orders issued by the Trump Administration that effectively banned certain Chinese connected software applications (“apps”) from operating in the United States. Although EO 14034 revokes these legal authorities and calls for their implementing rules to be rescinded, EO 14034 signals that the Biden Administration will continue to analyze the national security risks presented by apps developed by persons subject to the jurisdiction or control of “foreign adversaries” and suggests that additional restrictions may be issued in the future.

On 1 June 2021, the US Treasury Department’s Office of Foreign Assets Control published the Burma Sanctions Regulations to implement Executive Order 14014, “Blocking Property With Respect to the Situation in Burma”. This imposed sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government.

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (EO 13959) and revokes Executive Order 13974 (EO 13974) that restricted investments in certain “Communist Chinese Military Companies” (CCMCs).

On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (EO 13959) and revokes Executive Order 13974 (EO 13974) that restricted investments in certain “Communist Chinese Military Companies” (CCMCs)

On April 20, 2021, the Biden Administration took steps to address cybersecurity risks in the US energy sector industrial base by announcing a 100-day cybersecurity initiative for electricity subsector industrial control systems (“100-Day Plan”) and by issuing, on April 22, 2021, a Request for Information to inform future recommendations for US energy systems’ supply chain security (“RFI”).

On April 20, 2021, the Biden Administration took steps to address cybersecurity risks in the US energy sector industrial base by announcing a 100-day cybersecurity initiative for electricity subsector industrial control systems and by issuing, on April 22, 2021, a Request for Information to inform future recommendations for US energy systems’ supply chain security.