On November 12, 2020, President Trump signed Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “China Securities EO”), which aims to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases of…
On November 13, 2020, the Trump Administration issued Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “China Securities EO”), which aims to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases…
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 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked…
On September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same…
On August 27, 2020 the Department of Commerce’s Bureau of Industry and Security (“BIS”) published a long-awaited advance notice of proposed rulemaking (“ANPRM”) seeking public comment on criteria for identifying “foundational technologies” that are essential to US national security with a view to imposing export controls on such uncontrolled technologies. BIS will…
On August 6, 2020, the Federal Emergency Management Agency (“FEMA“) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (“PPE Products“) used in the response to the COVID-19 pandemic (“Extension Rule“). The original restrictions on…
On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”). Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the…
On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”). Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the…
On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in…