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Lise Test

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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.

On 19 May 2020, the US Commerce Department’s Bureau of Industry and Security (BIS) published an interim final rule effective on 15 May 2020 amending the Export Administration Regulations’ (EAR) General Prohibition Three (the foreign-produced direct product rule) and Entity List to impose new controls on the reexport, export from abroad, and transfer (in-country) of certain foreign-produced semiconductor-related items when such items are the direct product of certain designated US technology or software and are destined to Huawei Technologies Co. Ltd. and 114 of its non-US affiliates designated on the BIS Entity List (collectively, Huawei). BIS is seeking comments on the interim final rule, which must be submitted on or before 14 July 2020.

On 28 April 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (EAR) to tighten restrictions on exports of technology to China, Russia, and Venezuela.

On April 1, 2015, President Obama issued an Executive Order (the “Cyber EO”) authorizing the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) to designate as Specially Designated Nationals (“SDNs”) certain persons that have engaged in “significant malicious cyber-enabled activities.” No party has yet been designated under the Cyber EO. OFAC…

On 9 March 2015, US President Barack Obama issued a new Executive Order(“Order”) authorizing the imposition of sanctions targeting Venezuela in response to the Venezuelan Government’s erosion of human rights guarantees; persecution of political opponents; curtailment of press freedoms; use of violence and human rights violations and abuses in response to…