During the first two weeks in January, the Office of Foreign Assets Control (OFAC) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the…

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,…

Over the past two weeks, the Office of Foreign Assets Control (“OFAC”) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the development of…

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 October 29, 2020, the Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule (the “final rule”) amending the license review policy under the Export Administration Regulations (EAR) for items controlled for national security (“NS”) reasons when destined to China, Russia, or Venezuela. The amendments add Venezuela to the…

The US Government continues to implement measures intended to restrict the provision or use of Chinese-origin goods and technology.  Notably, on July 14, 2020, three government agencies issued an interim rule (the “Interim Rule”) that implemented changes to the Federal Acquisition Regulations (“FARs”) pursuant to Section 889 of the National…

On October 9, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the comment period for the advance notice of proposed rulemaking (ANPRM) on criteria of “foundational technologies.” Comments may now be submitted through November 9, 2020; two weeks after the original deadline of October 26. BIS also clarified it…

On July 31, 2020, the Department of Commerce Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to suspend the availability of all License Exceptions for Hong Kong that provide differential treatment relative to mainland China. Our blog post on prior steps taken to revoke preferential treatment…

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published four Frequently Asked Questions (the “FAQs”) regarding Iran-related sanctions under Executive Order 13902 (“EO 13902”).  EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged…

On July 14, 2020, President Trump issued Executive Order 13936 “The President’s Executive Order on Hong Kong Normalization” (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong…