The latest on Russia sanctions from the International Trade and Supply Chain Team
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As we discussed in a recent client alert, the U.S. Department of Commerce recently issued a proposed rule (the “Proposed Rule”) which intends to give the U.S. Secretary of Commerce the authority to block, unwind or modify information and communications technology or services (“ICTS”) transactions involving “foreign adversaries” if the Commerce Secretary determines that such transactions threaten U.S. critical infrastructure, the U.S. digital economy or U.S. national security. There were many aspects of the Proposed Rule which were unclear, but the U.S. Department of Commerce indicated its willingness to consider comments from the public which were received on or before Friday, December 27, 2019.

On Monday, December 23, 2019 the U.S. Department of Commerce announced that it had extended the Proposed Rule’s comment period in order to consider comments received before the close of business on Friday, January 10, 2020. This extension will provide potential respondents with an additional 14 days to prepare comments to the Proposed Rule.

If you have questions about the proposed rule please contact Cortney Morgan or Grant Leach with Husch Blackwell’s Export Controls & Economic Sanctions Team or Mindi Giftos or Bob Bowman with Husch Blackwell’s Data Privacy, Cybersecurity & Breach Response Team.