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Export Control


This week’s Government Enforcement video discussion, led by Baker McKenzie’s Tom Firestone and Jerome Tomas, will cover topics such as the Russian response to US sanctions, the trial of Mayor of Fall River, Massachusetts for extorting marijuana businesses, SEC Commissioner Peirce’s statement on an Index Fund SEC settlement, and the SEC and cyrpto assests.

On April 28, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule amending and reissuing the Somalia Sanctions Regulations, 31 C.F.R. Part 551 (“Regulations”) to further implement two existing Executive Orders, Executive Order 13536 of April 2010 and Executive Order 13620 of July 2012, and to replace the prior Somalia Sanctions Regulations that were published in May 2010 in abbreviated form.

On 5 January 2021, the Kingdom of Saudi Arabia, the United Arab Emirates, Bahrain and the rest of the Gulf Cooperation Council (GCC) member states, along with Egypt, signed the “Al-Ula Declaration” at the 41st GCC Summit held in the city of Al-Ula. This marks the end of a three and a half year boycott against the State of Qatar, which was put in place in June 2017, paving the way for the re-establishment of political and economic ties with Qatar.

On 10 May, the Council of the European Union adopted a revised version of the EU’s Dual-Use Regulation. Key changes include two new general export authorisations, stricter controls on cyber-surveillance and technical assistance, changes to the licensing framework, and provisions allowing for increased co-ordination between Member States.

On May 12, 2021, the US International Trade Commission (USITC) announced that it had issued a report recommending that the President make certain modifications to the Harmonized Tariff Schedule of the United States (HTS) to conform it with World Customs Organization (WCO) amendments to the global Harmonized System. The USITC’s report, Recommended Modifications in the Harmonized Tariff Schedule, 2021, Inv. No. 1205-13, USITC Publication 5171, March 2021, is available on the USITC web site.