The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued final rules amending the Export Administration Regulations (“EAR”) by implementing new export controls on Burma (Myanmar), and adding
Continue Reading BIS Implements New Burma Export Controls and Adds Four Entities to the Entity List

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
Continue Reading U.S. Imposes Targeted Sanctions and Export Restrictions on Burma in Response to Military Coup

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.
Continue Reading Commerce Publishes Interim Final Rule Addressing “Foreign Adversaries” in ICTS Supply Chain

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 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