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Iris Zhang

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On March 29, 2021, the US Department of Commerce’s Bureau of Industry and Security published a final rule implementing changes to the Export Administration Regulations that were agreed to at the December 2019 Wassenaar Arrangement Plenary meeting. Specifically, the Final Rule modified the reporting and self-classification requirements for exports of most mass-market encryption items and the email notification requirement for exports of publicly available encryption source code and beta test software.

On March 2, 2021, the US Government imposed a series of new measures against Russian Government officials and entities in response to the alleged poisoning and subsequent imprisonment of Russian opposition politician Aleksey Navalny.  Specifically, the US State Department (State) imposed a number of financial sanctions and export restrictions on…

On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (“EAR”) to implement certain provisions of the Export Control Reform Act of 2018 (“ECRA”).  Among other things further outlined below, the Rule imposes new restrictions on…

On January 19, 2021, then President Trump issued Executive Order 13984 (“EO 13984”), “Taking Additional Steps To Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities” which amends and expands Executive Order 13694 of April 1, 2015, to detect and deter the use of US infrastructure as a service (“IaaS”)…

On January 1, 2021, the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA 2021”) was enacted into law after the US Congress voted to override the President’s veto of the bill. The defense budget legislation authorizes $740.5 billion for national defense spending and sets policies on military compensation, procurement of…

On December 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to revise the Country Group designations for Ukraine, Mexico, and Cyprus.  BIS has placed these countries’ into more permissive Country Groups due to these countries’ membership in…

On December 23, 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule amending the Export Administration Regulations (EAR) by adding a new “Military End User List” (MEU List) as supplement no. 7 to part 744 of the EAR. The final rule adds 102 entities to the MEU List,…

On October 26, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated additional Iranian individuals, entities and vessels to the Specifically Designated Nationals and Blocked Persons List (the “SDN” List) pursuant to Executive Order 13224 (as amended) (EO 13224), a counter-terrorism authority, for their support to Iran’s Islamic…

On September 24, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Final Rule in the Federal Register that amended the Cuban Assets Control Regulations (“CACR”) to further implement the President’s foreign policy to deny the Cuban regime sources of revenue. Major elements of the changes include: Professional (Including Business)…