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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 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.

On May 16, 2022, the US Departments of State and Treasury and the Federal Bureau of Investigation issued a joint advisory alert to the public about attempts by the Democratic People’s Republic of Korea (“DPRK” a.k.a. North Korea) and DPRK information technology (“IT”) workers posing as non-DPRK nationals to obtain employment outside of North Korea. The Advisory provides guidance to help prevent inadvertent recruitment, hiring, and facilitation of North Korean IT workers, as the hiring or support of DPRK IT workers may create business risks that range from theft of data, intellectual property, and funds, to sanctions-related risks under both US and United Nations authorities.

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.