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Bart M. McMillan

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Bart McMillan leads the Chicago Office’s International Trade Compliance Subpractice within the North American International Commercial Practice. He advises US and non-US companies on international trade compliance matters arising under US export controls, trade sanctions, and antiboycott rules, as well as under US customs laws with respect to classification, valuation, country of origin, free trade agreements, and the protection of intellectual property at the US border. His practice also covers anti-bribery and specialized commercial compliance issues in sales and sales promotion under the US Foreign Corrupt Practices Act (FCPA), non-US anti-bribery law, and non-US commercial laws. Mr. McMillan has been practicing with Baker McKenzie for the entirety of his legal career, and during 2004 he was located in the Washington, DC office. He is a frequent speaker on international trade compliance matters at seminars, conferences, and company training events. While pursuing his J.D. at NYU School of Law, Mr. McMillan was Staff Editor (1997-98) and Associate Editor (1998-99), New York University Law Review; and he participated in a semester exchange to the Central European University (Budapest) (Legal Studies Dep’t).
In Sanctions

United States: Government Designates Russian Proxy Wagner Group as a Significant Transnational Criminal Organization

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Baker McKenzie’s Sanctions Blog published the alert titled US Government Designates Russian Proxy Wagner Group as a Significant Transnational Criminal Organization; Sanctions Wagner Group Affiliates, Oligarch Affiliates, and Military Industrial Complex Firms on 31 January 2023. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

In Sanctions

United States: OFAC and BIS Designate Additional Russian Parties, Signal Readiness to Act Against Third-Country Entities Assisting Russia and Belarus

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Baker McKenzie’s Sanctions Blog published the alert titled OFAC and BIS Designate Additional Russian Parties, Signal Readiness to Act Against Third-Country Entities Assisting Russia and Belarus on 5 October 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

In Sanctions

United States: OFAC amends existing and issues new General Licenses under Russia sanctions to authorize pension payments to non-US persons outside of Russia and closing individual accounts at blocked banks

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Baker McKenzie’s Sanctions Blog published the alert titled OFAC amends existing and issues new General Licenses under Russia sanctions to authorize pension payments to non-US persons outside of Russia and closing individual accounts at blocked banks on 29 August 2022. Read the article via the link here. Please also visit ourSanctions Blog for the most recent updates.

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United States: BIS announces new policy changes to strengthen its existing administrative enforcement program

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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.

In Trade and Foreign Investment

United States: BIS Adds to Entity List and Imposes License Requirement for Food/Medicine to Russian/Belarussian Military End Users; Commerce Charging Letters to Become Public

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Baker McKenzie’s Sanctions Blog published the alert titled BIS Adds to Entity List and Imposes License Requirement for Food/Medicine to Russian/Belarussian Military End Users; Commerce Charging Letters to Become Public on 1 July 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

In Sanctions

United States: Biden Administration relaxes certain limited Cuban sanctions

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On 16 May 2022, the Biden administration announced the relaxing of certain limited Cuban sanctions and other regulatory changes to expand communication, travel, and commerce between the United States and Cuba. Following this, on 9 June 2022, the Department of the Treasury’s Office of Foreign Assets Control amended the Cuban Assets Control Regulations to implement some of the elements of the President’s foreign policy to increase support for the Cuban people.

In North America

United States: OFAC Re-Issues and Revises Two General Licenses Related to GAZ Group Narrowing Authorized Activities and Implementing Reporting Requirements; Updates Corresponding FAQs

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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.

In Global

2021 Virtual Year-End Review of Import/Export Developments

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Baker McKenzie’s international trade compliance lawyers from around the world discussed the major global legislative, judicial and administrative activities and trends in export controls, trade sanctions, customs compliance, and import requirements in nine 75 minute sessions which took place from 16 to 18 November 2021.