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Lise S. Test

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Lise Test is an of counsel in the Firm’s International Trade Group in Washington, DC and practices in the area of international trade regulation and compliance — with emphasis on US export control laws (Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR)), trade sanctions, and anti-boycott laws. Ms. Test advises clients on issues relating to product classifications, licensing, regulatory interpretations, risk assessments, enforcement actions, internal investigations and compliance audits, as well as the design, implementation, and administration of compliance programs. Ms. Test works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, telecommunications, manufacturing, and technology sectors. She joined the Firm as a summer associate in 2007 and became a full-time associate in 2008. Prior to joining Baker McKenzie, Ms. Test served as a lawyer at the Danish Ministry of Defence.

On November 26, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls issued General License 41 authorizing Chevron Corporation to resume limited oil extraction operations in Venezuela and accompanying FAQs. According to the accompanying press release, OFAC issued GL 41 after Unitary Platform and President Maduro’s regime announced the resumption of negotiations; a humanitarian agreement focused on education, health, food security, flood response, and electricity programs that will benefit the Venezuelan people; and agreement on the continuation of talks focused on the 2024 elections. OFAC also issued an updated General License 8K extending certain limited wind-down activities with Petróleos de Venezuela SA until 25 May 2023.

Welcome to our Virtual Year-End Review of Import/Export and Trade Compliance Developments Conference resource center. 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 15 to 17 November 2022.

On 17 October 2022, OFSI and OFAC issued a joint statement to reiterate the close working relationship between the two agencies, explaining the rationale behind increased OFSI-OFAC co-operation and how this will manifest in practice. The statement follows a technical exchange attended by OFAC and OFSI in London, which concluded on 13 October 2022.

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.

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 BIS adds foreign-produced aircraft to list of aircraft exported to Russia in apparent violation of the EAR and OFAC issues new and amended Russia general licenses on 22 August 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security issued a final rule updating the scope of License Exceptions Authorized Cybersecurity Exports Encryption Commodities, Software, and Technology related to cybersecurity items in response to public comments on the interim final rule related to cybersecurity items published on 21 October 2021. The interim final rule established a new control on certain cybersecurity items for National Security and Anti-terrorism reasons and created License Exception ACE in Section 740.22 of the Export Administration Regulations, which authorizes exports of identified cybersecurity items to most destinations except in certain circumstances.