On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”). This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period. The federal…
On November 17, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) amending and clarifying certain provisions of the Export Administration Regulations (“EAR”) to make them consistent with the Export Control Reform Act of 2018 (“ECRA”). The Final Rule also amends…
On October 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published a final rule amending the Cuban Assets Control Regulations (CACR) restricting certain remittance-related transactions to and from Cuba (the “Final Rule”). OFAC also published updated and new Frequently Asked Questions (FAQs) related to transactions with Cuba. Significantly, the recent amendments…
On September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same…
On August 27, 2020 the Department of Commerce’s Bureau of Industry and Security (“BIS”) published a long-awaited advance notice of proposed rulemaking (“ANPRM”) seeking public comment on criteria for identifying “foundational technologies” that are essential to US national security with a view to imposing export controls on such uncontrolled technologies. BIS will…
On August 6, 2020, the Federal Emergency Management Agency (“FEMA“) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (“PPE Products“) used in the response to the COVID-19 pandemic (“Extension Rule“). The original restrictions on…
On July 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding eleven Chinese entities to the Entity List (the “XUAR Designees”) due to their alleged involvement in human rights abuses including mass arbitrary detention, forced labor, involuntary collection of biometric data, and…
On 15 April 2020, the US Departments of State, Homeland Security, and the Treasury (Treasury), and the Federal Bureau of Investigation issued an advisory warning about the cyber threat posed by North Korea, calling particular attention to banks and other financial institutions (Advisory).
On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”) notifying Congress of its intent to terminate the sanctions imposed on En+ Group plc (“En+”), UC Rusal plc (“RUSAL”), and JSC EuroSibEnergo (“ESE”) in 30 days. …