The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently issued General License 13E (“GL 13E”), authorizing certain activities involving Nynas AB, a Swedish manufacturer of specialty oils owned in part by PDVSA, Venezuela’s state-owned oil company, which would normally be prohibited by Executive Order 13850 (“E.O. 13850”). The notice issued by OFAC
OFAC Issues Two New General Licenses for Companies Doing Business with GAZ Group
The U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) has recently issued two new General Licenses to extend pre-existing authorizations for transactions with GAZ Group that would otherwise be prohibited under OFAC’s Ukraine- and Russia-related sanctions. General License 15H (“GL 15H”) authorizes certain activities necessary to maintenance or wind down of operations or existing contracts
BIS Renews Huawei Temporary General License and Requests Comments on Future Renewals
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced the issuance of yet another extension of the temporary general license (TGL) allowing companies to continue business with Huawei Technologies Co., Ltd. and its 114 subsidiary and affiliate companies that are currently named on BIS’s Entity List. The TGL was scheduled to expire
BIS Sets Date for 2020 Export Controls Update Conference
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has announced that its 33rd Annual Conference on Export Controls will take place in Washington, D.C. from June 29 to July 1, 2020. The conference attracts attendees from various sectors to learn about and discuss relevant export control issues. The Annual Conference will
Certain Firearms, Ammunition and Accessories To Undergo Export Regulation Update
On Thursday, January 23, 2020, the U.S. Department of State – Directorate of Defense Trade Controls (“DDTC”) and U.S. Commerce Department – Bureau of Industry and Security (“BIS”) published new coordinated final rules which will take effect on Monday, March 9, 2020. On that date, the DDTC rule will remove specifically identified firearms, ammunition, accessories
Trump Administration Expands Iran Sanctions to New Sectors in Recent Executive Order
In a January 10th Executive Order, President Trump expanded sanctions on Iran after a ballistic missile attack on two American military bases in Iraq. Executive Order 13902 expands secondary sanctions on Iran to include “significant” or “material” support transactions between non-U.S. persons and Iran’s construction, mining, manufacturing, and textiles sectors as potentially sanctionable
International Trade Law: 2019 Year in Review & 2020 Outlook
As we kick off a new year, Husch Blackwell’s International Trade and Supply Chain team offers an analysis of events that shaped the international trade landscape in 2019 as well as insight into what international trade issues are on the horizon in 2020 in a recently published white paper.
The “International Trade Law: 2019
Commerce Department Extends Comment Period for Foreign Adversary ICTS Rule
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.
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Trump Administration Grants 90-Day Extension of TGL for Companies Doing Business with Huawei
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced on Monday, November 18, 2019 the issuance of a new 90-day extension which will allow U.S. companies to continue doing business with Huawei Technologies Co. Ltd. (“Huawei”) under the Temporary General License (“TGL”). BIS did not make any changes to the TGL other
BIS Extends Huawei Temporary General License with Major Changes and Adds New Affiliates to Entity List
In May of 2019, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added Chinese telecommunications giant Huawei Technologies Co. Ltd. (“Huawei”) and sixty-eight of its affiliated companies to BIS’s Entity List. These designations prohibit anyone, anywhere in the world from exporting, re-exporting or making an in-country transfer of “items subject to the EAR” to the listed Huawei Companies (“Items subject to the EAR” generally consist of US-origin commodities, software or technology, items produced outside the US which include qualifying US-origin content and items that are physically present in or transiting through the US). Shortly after making these designations, BIS issued a Temporary General License which authorized limited ongoing transactions with Huawei to support existing networks and Huawei equipment and handsets.
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