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Lise S. Test

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 23 August 2023, the US Treasury Department’s Office of Foreign Assets Control issued the first Determination Pursuant to Section 1(a)(i) of Executive Order 14014, which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions: FAQ 1132 and FAQ 1133.

On 8 August 2023, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the OFAC Compliance Communique: Guidance for the Provision of Humanitarian Assistance to Syria. The guidance responds to specific questions that OFAC received from the non-governmental organization (NGO) community and the general public related to the provision of humanitarian assistance to the Syrian people. In addition, OFAC amended Frequently Asked Question 937 related to the Syria NGO general license.

Baker McKenzie’s Sanctions Blog published the alert titled  OFAC and OFSI Issue Joint Humanitarian Assistance and Food Security Fact Sheet Relating to Russia on 11 July 2023. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.  

On 11 May 2023, the Committee on Foreign Investment in the United States (CFIUS) issued a Frequently Asked Question (FAQ), which calls into question the use of “springing rights,” a broadly used instrument to expedite financings while complying with mandatory filing requirements. The FAQ addresses the timing for when a filing must be made for a transaction triggering a mandatory filing. Since implementation of the mandatory filing requirements, transaction parties have used springing or deferred rights to allow financings to proceed while those rights triggering a CFIUS filing are deferred or held in abeyance until after CFIUS clearance.

On 30 March 2023, the White House and US Department of Commerce’s Bureau of Industry and Security announced human rights and export control measures that underscore the US Government’s focus on human rights as a matter of foreign policy. The White also issued a Fact Sheet that includes these announcements and other sanctions and export control provisions.

On 21 February 2023, the US Department of the Treasury’s Office of Foreign Assets Control issued OFAC Compliance Communique: Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria. The Guidance responds to specific questions OFAC received related to earthquake relief efforts in Syria and explains how to provide humanitarian assistance to the Syrian people in compliance with US sanctions.

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.