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Daniel Andreeff

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Daniel Andreeff is an associate in the Firm’s International Trade practice group in Washington, DC. Prior to joining the Firm, he interned with the Department of the Treasury’s Office of Foreign Assets Control.

On 23 December 2022, President Biden signed into law the National Defense Authorization Act for Fiscal Year 2023. Section 5949 of the FY2023 NDAA would prohibit executive agencies from procuring or contracting with entities to obtain any electronic parts, products, or services that include covered semiconductor products or services from certain Chinese companies. The semiconductor prohibitions will not take effect until five years after the date of enactment, and the Federal Acquisition Regulatory Council will issue regulations implementing the prohibitions no later than three years from the enactment date.

On 16 December 2022, the US Department of State’s Directorate of Defense Trade Controls issued a proposed rule that would treat two additional types of transactions as activities that are not exports, reexports, retransfers, or temporary imports (“controlled events”) (and, thus, not require authorization) under the International Traffic in Arms Regulations.

On 6 October 2022, the Assistant Secretary for Export Enforcement issued a policy aimed at enhancing enforcement of the antiboycott rules administered by the US Department of Commerce. The following day a final rule came into effect updating Department of Commerce’s guidance on charging and penalty determinations related to violations of the antiboycott provisions of the Export Administration Regulations. The changes are intended to bring penalty determinations in line with the Department of Commerce’s current view of the severity of certain types of antiboycott violations.

Baker McKenzie’s Sanctions Blog published the alert titled BIS issues new FAQs addressing red flags related to Russia/Belarus and semiconductor foundries’ potential entity list dealings on 1 September 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

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.

Baker McKenzie’s Sanctions Blog published the alert titled OFAC Issues New General Licenses Authorizing Certain Transactions with the Central Bank of the Russian Federation, Designates Additional Russian Parties as SDNs, and Issues New Guidance on 8 March 2022. Read the article via the link here . Please also visit our Sanctions Blog for the most recent updates.

On 19 August 2021, the Federal Communications Commission published a notice of proposed rulemaking discussing potential changes it is considering making to its equipment authorization and competitive bidding programs to restrict the use of telecommunications and video surveillance equipment and services produced or provided by five Chinese companies.

On June 8, 2021, the White House published a set of reports on the 100-day interagency reviews (“Reports”) conducted pursuant to Executive Order 14017 (“Supply Chain EO”), which assessed supply chain risks and vulnerabilities for several supply chains, including those relating to semiconductor manufacturing and advanced packaging, and made policy recommendations to address those risks.