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Andrea Tovar

Andrea Tovar regularly advises multinational companies on cross-border commercial transactions and complex privacy and international trade matters. Andrea is also a member of the Firm’s Technology, Media & Telecoms Global Industry Group and Co-Chairs the North America Baker Unidos Affinity Group.

Businesses that have implemented compliance measures to comply with the California Consumer Privacy Act of 2018, as amended by the California Consumer Rights Act of 2020 (CCPA) can leverage existing vendor contract terms, website disclosures and data subject right processes to satisfy requirements under Nevada’s Revised Statutes Chapter 603A. Most companies will not need to expand the scope of CCPA-focused privacy notices because the Nevada laws are much more narrowly framed. But, companies may find it operationally efficient to broaden the scope of opt-out rights if they engage in data sharing practices that qualify as “selling” of personal information, for example, in the context of digital advertising.

On June 30, 2022, the US Department of Commerce’s Bureau of Industry and Security announced four key policy changes to strengthen the administrative enforcement program and tackle external threats. These policy changes prioritize the “most serious violations” and cases that pose the greatest danger to US security.

Baker McKenzie’s Sanctions Blog published the alert titled United States: BIS Issues Temporary Denial Order Against Additional Russian Airline and Adds Aircraft to List of Aircraft Subject to General Prohibition 10 on 2 June 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

On April 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued General License 13R (“GL 13R”) and General License 15L (“GL 15L”), narrowing those authorized activities with GAZ Group and entities owned 50% or more by GAZ Group (“GAZ”), as further described below. OFAC also issued a set of updated FAQs to clarify the scope of authorized activities under these GLs.

On December 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Chinese tech companies to the Non-SDN Chinese Military-Industrial Complex Companies (“NS-CMIC”) list pursuant to Executive Order 13959, as amended by Executive Order 14032, for their alleged involvement in supporting surveillance of ethnic and religious minorities in Xinjiang, China. On the next day, the US Commerce Department’s Bureau of Industry and Security (“BIS”) also added 37 new parties to the BIS Entity List, including 25 Chinese companies for their alleged involvement in efforts to develop and use biotechnology and other technologies for military application and human rights abuses. These sanctions are part of an increase in US Government efforts to prevent alleged human rights abuses.

On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 to authorize nongovernmental organizations to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria.

On November 10, 2021, the US Departments of State, Treasury, and Commerce issued a joint advisory (the “Advisory”) cautioning US companies operating in or considering operations in Cambodia to be conscious of dealings with entities and in sectors potentially involved in human rights abuses, criminal activities, and corrupt business practices. We describe the Advisory in additional detail below.

On August 11, 2021, the US Treasury Department’s Office of Foreign Assets Control and the Commerce Department’s Bureau of Industry and Security issued a joint Fact Sheet: Supporting the Cuban People’s Right to Seek, Receive, and Impart Information through Safe and Secure Access to the Internet and a related press release.

In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. These represent the first major escalation of sanctions against Russia under the Biden Administration. 3. SEO Key words: Sanctions, Cyber Security, Export Control, Customs, Trade Policy, United States, Russia, Technology, Debt, Loans, SolarWinds