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)…

On August 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (“DOT”) suspend private charter flights to all Cuban airports.  This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized…

The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”).  These changes by DDTC were prompted by the COVID-19 crisis and…

On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”).  Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the…

On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”).  Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the…