On February 1, 2021, the military of Burma (Myanmar) in an unanticipated coup d’état installed General Min Aung Hlaing as leader and detained the country’s top elected leaders, including the President and Prime Minister. In response, on February 10, 2021, President Biden issued Executive Order 14014 (the “E.O.”) authorizing the U.S. Department of Treasury’s (“Treasury”)
The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) published regulations in the Federal Register on January 15, 2021 to implement Executive Order 13936 (“E.O. 13936”), titled “The President’s Executive Order on Hong Kong Normalization.” The President determined on July 14, 2020 in E.O. 13936 that Hong Kong was no longer sufficiently autonomous
On January 19, 2021, the U.S. Department of Commerce (Commerce) published a long-awaited interim final rule to address the use of goods or services sourced from “foreign adversaries” in the U.S. supply chain for information communications technology and services (ICTS) transactions. When the interim final rule (ICTS Rules) take effect on March 20, 2021, they will enable the U.S. Secretary of Commerce (the Secretary) to block any ICTS transaction involving goods or services designed, developed, manufactured or supplied from “foreign adversaries” or companies organized in a “foreign adversary” country, conducting operations in a “foreign adversary” country or otherwise subject to the direction or control of a “foreign adversary.” These rules will have especially broad application, but Commerce has also indicated that it will continue to accept comments on the rules for the next 60 days. Commerce will also publish procedures for a “safe harbor” licensing program within the next 60 days and will then implement that licensing program within the next 120 days. Therefore, concerned parties still have an opportunity to submit feedback on the ICTS Rules and also have some remaining time to evaluate whether their transactions or activities might require licensing from Commerce.
On January 14, 2021, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it has amended the Export Administration Regulations (“EAR”) to formally implement the rescission of Sudan’s designation as a State Sponsor of Terrorism (“SSOT”), which was rescinded by the Secretary of State on December 14, 2020. BIS has amended
The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule amending the Export Administration Regulations (“EAR”) to add 77 entities to the Entity List. This rule took effect on Friday, December 18, 2020 when BIS made a copy available for public inspection on the Federal Register website.
As a
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.
The U.S. Department of State announced that Sudan’s designation as a “State Sponsor of Terrorism” has been officially rescinded effective December 14, 2020. In October, the President notified Congress that Sudan’s designation would be rescinded and certified that Sudan had not provided support for acts of terrorism within the last six months, and that Sudan
The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned CEIEC (China National Electronic Import-Export Company), a Chinese technology exporter, for its alleged support to the Maduro government in Venezuela. As a result of CEIEC’s addition to OFAC’s Specially Designated Nationals List, all property and interests belonging to CEIEC, or any entity
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.
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.