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Caroline Howard

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Caroline Howard is an associate in the Washington, DC office where she is a member of the International Commercial Practice Group. Her practice is focused on all aspects of international trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. She represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS). Prior to joining the Firm, Caroline worked in telecommunications law. Specifically, she handled applications for international Section 214 authorizations, which included helping clients navigate Team Telecom's specific national security review for foreign participation in the US telecommunications sector.

On 20 October 2022, the US Treasury Department released the first Committee on Foreign Investment in the United States Enforcement and Penalty Guidelines. The Guidelines provide visibility into factors CFIUS considers when assessing violations of CFIUS laws and regulations, and determining potential penalties. The Guidelines are applied by the Monitoring and Enforcement office, which is part of the US Treasury Department’s Office of Investment Security.

On 7 October 2022, the US Commerce Department’s Bureau of Industry and Security issued the much anticipated rules aimed at restricting China’s ability to obtain advanced computing chips, develop and maintain supercomputers, and manufacture advanced semiconductors. In addition to formalizing the licensing requirements included in the recent BIS “is informed” letters issued to certain US companies on related matters, the Rule imposes a wide range of new and enhanced restrictions targeting China’s advanced computing and semiconductor sectors.

On 9 September 2022, the US Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule revising the Export Administration Regulations to authorize the release of certain technology and software in the context of “standards-related activity” involving entities listed on the Entity List. Comments on the impact of this action on participation in “standards-related activity” must be submitted to BIS no later than 8 November 2022.

Baker McKenzie’s Sanctions Blog published the alert titled US Government Sanctions More than 100 Russia-Related Parties and Prohibits the Import of Russian Gold in Coordination with G7 Allies on 1 July 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

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.

Baker McKenzie’s Sanctions Blog published the alert titled BIS expands sanctions against Russia and Belarus and adds four countries to global export controls coalition on 12 April 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.