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The U.S. Department of State issued updated public guidance on Section 232 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), which authorizes the president to impose sanctions on persons engaged in certain investments or other activities with respect to Russian energy export pipelines.  Effective on July 15, 2020, the actions that are sanctionable under…

In collaboration with our foreign law firm partners, we continue to update our chart of COVID-19 measures taken by governments around the world. The government measures in the chart include economic, labor and employment, health and safety, and export and import measures. Below is a list of the updated countries and a summary of the…

On June 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it would be delaying the effective date for certain filing requirements set forth in April 2020 regulations on military-related exports to China, Russia and Venezuela. After significant pushback from industry representatives that more time was needed to transition to…

In collaboration with our foreign law firm partners, we continue to update our chart of COVID-19 measures taken by governments around the world. The government measures in the chart include economic, labor and employment, health and safety, and export and import measures. Below is a list of the updated countries and a summary of the…

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued two final rules and one proposed rule intended to prevent efforts by entities in China, Russia and Venezuela to acquire U.S. technology that could be used in development of weapons, military aircraft or surveillance technology through civilian supply chains or under civilian-use pretenses.…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced its extension of two general licenses related to GAZ Group, Ukraine-related General License No. 13N, “Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in GAZ Group” and Ukraine-related General License No. 15H, “Authorizing Certain Activities…

Recently, the U.S. Trade Representative (USTR) issued its annual reports to Congress assessing how the People’s Republic of China (China) and the Russian Federation (Russia) have been complying with their World Trade Organization (WTO) accession agreements, including both their multilateral commitments and bilateral commitments with the United States.  China became a member of the WTO…

On February 24, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Federal Register notice announcing amendments to the Export Administration Regulations (EAR) that revise export licensing policy toward the Russian Federation and Yemen based on national security and foreign policy concerns. Under the EAR, BIS has established various “Country Group”…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eight individuals and one entity in response to Russia’s continued aggression toward Ukraine and attempted occupation of Crimea, which the United States continues to view as an illegitimate annexation since it occurred in 2014. OFAC has designated and placed on the Specially…

In September, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) continued to tighten its sanctions on Iran and Venezuela, and addressed a sanctions-evading scheme for Syria involving several Russian entities.

  • Iran: On September 20, 2019, OFAC announced that it was designating the Central Bank of Iran (CBI), the National Development

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