January 2017

The newly passed Cybersecurity Law of the People’s Republic of China will take effect in June 2017, and it is expected to have a significant impact on multinationals doing business in mainland China. The law affects both domestic and foreign companies operating on the Chinese mainland and covers a wide range of activities including the use of the internet, information and communications technologies, personal data, national security and more.

The difficulties with determining the steps needed to comply with such sweeping changes are only complicated by the fact that a large number of key terms in the law have yet to be clearly defined. As a result, China’s new Cybersecurity Law will continue to evolve as the national government interprets it.

Here are some key provisions to follow in the coming months.

In the last few days of his Administration, President Obama and the U.S. Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) took actions that, on at least a temporary basis, will authorize financial transactions with and most exports of goods and services to Sudan and the Sudanese Government. These actions take effect on Tuesday, January 17, but any U.S. persons seeking to trade with Sudan under the expanded authorizations should be aware that these new authorizations are subject to various conditions and could be revoked or modified based on future actions by the Government of Sudan and/or President-Elect Donald Trump’s incoming administration.

Following the recent release of a joint analysis report by the Federal Bureau of Investigation (FBI) and department of Homeland Security (DHS) on Russian Malicious Cyber Activity and sanctions issued by the Obama Administration on December 29, 2016 (as previously reported here), the Department of Commerce’s Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) by adding five (5) Russian entities to the Entity List.  The entities identified below have been determined to have been involved in activities contrary to the national security or foreign policy interests of the United States: