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Lise Test

Lise Test, an associate in Baker & McKenzie’s International Trade Group in Washington, DC, practices in the area of international trade regulation and compliance — with emphasis on US export control laws, trade sanctions, anti-boycott laws and the Foreign Corrupt Practices Act. Prior to joining Baker & McKenzie, Ms. Test served as a lawyer at the Danish Ministry of Defence where she focused on international public law and Danish torts, administrative law and military criminal law. In addition to her practice, Ms. Test also taught international humanitarian law and contract law at the Danish Royal Naval Academy.

Baker McKenzie’s Sanctions Blog published the alert titled US Government Issues New Executive Order Prohibiting Certain Imports, Exports, and New Investments Involving Russia and Four New General Licenses Related to Operations in Russian and Ukraine on 15 March 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

On 10 December 2021, at the Summit for Democracy, the US, Australia, Denmark, and Norway, released a Joint Statement announcing an Export Controls and Human Rights Initiative to curb the misuse of technologies by certain governments. The initiative aims to combat digital authoritarianism in countries where software and advanced surveillance technologies have been used to hack the communications of political opponents and journalists, shape public opinion, and censor information the government deems threatening.

Join us for our 19th Annual Global Trade and Supply Chain Webinar Series entitled, “International Trade Developments in a Challenging New World,” which includes the latest international trade developments. This year, in a variety of sessions, our panels of experts will cover the key developments and latest trends on sanctions, export controls and Foreign Investment Review regimes. On the inbound side, there will be sessions on opportunities and compliance challenges arising out of FTAs, hot topics on Customs valuation, trends in customs audits and supply chain compliance challenges and logistics.

On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 to authorize nongovernmental organizations to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria.

On November 18, 2021, President Biden signed Executive Order (“EO”) 14054 which terminates US sanctions related to Burundi by revoking EO 13712 of November 22, 2015. EO 13712 imposed sanctions related to Burundi due to “the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression” occurring in Burundi at the time and designated several parties as Specially Designated Nationals.

On November 3, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule adding the following four entities to the Department of Commerce Bureau of Industry and Security Entity List: Candiru (Israel), NSO Group (Israel), Computer Security Initiative Consultancy PTE (Singapore), and Positive Technologies (Russia). The addition of the four entities comes after the October 21, 2021 publication of an interim rule by BIS establishing controls on the export, re-export, and in-country transfers of items that may be used for malicious cyber activities and is part of the ongoing effort by the Biden-Harris Administration to combat the use of digital tools for repression.

On 21 September 2021, the US Treasury Department’s Office of Foreign Assets Control issued an updated ransomware advisory highlighting the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action. OFAC concurrently designated SUEX OTC, SRO as a Specially Designated National, the first designated virtual currency exchange.

On August 11, 2021, the US Treasury Department’s Office of Foreign Assets Control and the Commerce Department’s Bureau of Industry and Security issued a joint Fact Sheet: Supporting the Cuban People’s Right to Seek, Receive, and Impart Information through Safe and Secure Access to the Internet and a related press release.

On July 12, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Venezuela General License 40 (“GL 40”), “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” OFAC concurrently issued related FAQs (FAQ 914 and FAQ 915). Our previous blog posts about US sanctions targeting Venezuela are available here.

On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule, effective June 8, amending the Export Administration Regulations (EAR) to reflect the formal termination by the United Arab Emirates (UAE) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after August 16, 2020.