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Andrea Tovar

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Andrea Tovar regularly advises multinational companies on cross-border commercial transactions and complex international trade matters. Andrea is also a member of the firm’s Technology, Media & Telecommunications Global Industry Group and the California Diversity & Inclusion Committee.

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

On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (EO 14014), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance…

On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (EO 14014), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance…

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

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…