Export Controls & Economic Sanctions

The U.S. Department of State (“State Department”) announced the imposition of sanctions on Turkey’s Presidency of Defense Industries (“SSB”) pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The U.S. is sanctioning SSB over its procurement of the S-400 surface-to-air missile system from Russia’s Rosoboronexport (“ROE”). SSB is Turkey’s primary defense procurement entity and ROE is Russia’s main exporter of arms. As a result of Turkey’s actions, the U.S. is imposing full blocking sanctions on four SSB officials along with certain non-blocking CAATSA sanctions on the SSB entity.
Continue Reading U.S. Sanctions Turkey’s Defense Procurement Entity Over Its Purchase of Russian Missile System

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License 8G (“GL 8G”), which authorizes five (5) U.S. oil and gas companies to engage in transactions “ordinarily incident and necessary to the limited maintenance of essential operations, contracts or other agreements”, as well as transactions necessary to the wind down of operations in Venezuela involving Petroleos de Venezuela, S.A. (“PdVSA”) or any entity which PdVSA owns a 50% or greater interest and that were in effect prior to July 26, 2019.  Effective November 17, 2020, GL 8G replaces and supersedes GL 8F which was set to expire on December 1, 2020, effectively extending its deadline through 12:01 eastern daylight time on June 3, 2021.  GL 8G applies specifically to the following entities and their subsidiaries: Chevron Corporation, Halliburton, Schlumberger Ltd., Baker Hughes (a GE company), and Weatherford International, PLC.
Continue Reading OFAC Issues Venezuela General License 8G Extending Authorization of Certain Transactions for U.S. Oil & Gas Companies

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a final rule, effective November 18, 2020, which revises certain provisions of the Export Administration Regulations (“EAR”) to implement enforcement provisions pursuant to the Export Control Reform Act of 2018 (“ECRA”), which expanded the export control authorities available to the Secretary of Commerce.  BIS also amended the EAR with respect to the issuance of licenses and denial orders and the payment of civil penalties, not directly related to implementation of ECRA.
Continue Reading BIS Amends EAR to Implement Export Enforcement Provisions of Export Control Reform Act

The Trump Administration has encountered further setbacks in its efforts to prevent Chinese company ByteDance Ltd. (“ByteDance”) from providing its popular social media app TikTok in the U.S.  For background:
Continue Reading TikTok Legal Drama Continues to Unfold Across Multiple Courtrooms and Federal Agencies

President Trump issued an Executive Order (“E.O.”) on November 12, 2020 titled “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.”  The E.O., which will be published
Continue Reading Executive Order Prohibits U.S. Persons from Investing in “Communist Chinese Military Companies”

On November 2, 2020, the White House released a notice continuing the national emergency with respect to Sudan declared in Executive Order 13067 of 1997.  Secretary of State Mike Pompeo
Continue Reading White House Rescinds Sudan’s State Sponsor of Terrorism Designation, Continues National Emergency

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule effective October 29, 2020 amending Section 742.4(b)(7) of the Export Administration Regulations (“EAR”) to revise
Continue Reading BIS Amends License Review Policy for National Security Controlled Items Destined for China, Venezuela, and Russia