Sanctions

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On April 19, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License No. 2H under the Belarus Sanctions Regulations, representing a shift in the licensing policy for transactions with certain entities. Since October 2015, now revoked OFAC General License No. 2G had authorized transactions with these nine companies. The…

On April 15, 2021, President Biden issued an Executive Order (“E.O.”) on “Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation.”  The E.O.  establishes a new national emergency under which sanctions may be imposed against individuals and entities furthering specified harmful foreign activities of Russia against the United…

On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…

On April 2, 2021, President Joseph Biden issued an Executive Order terminating a previously declared national emergency and related sanctions against certain persons involved with the International Criminal Court (ICC). In June 2020, President Trump issued Executive Order 13928 declaring a national emergency due to the ICC’s “illegitimate assertions of jurisdiction over personnel of the…

On March 22, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese government officials for “serious human rights abuses” against ethnic minorities in the Xinjiang Uyghur Autonomous Region of China. In a brief press statement, the Director of OFAC stated, “Chinese authorities will continue to face consequences as long…

Note: This previously published client update has been revised to provide links to the official notices published by the Departments of Commerce and State on March 18, 2021.

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to…

The Commercial Customs Operations Advisory Committee (COAC) of U.S. Customs and Border Protection (CBP) has indicated that CBP intends to add forced labor to its list of priority trade issues. The COAC issued draft recommendations on how to “ensure a more holistic U.S. government-wide approach to addressing forced labor.” The COAC Forced Labor Working Group…

On March 12, 2021, the U.S. District Court for the District of Columbia issued a preliminary injunction which prohibits the Department of Defense (DOD)  from enforcing its January 2021 designation of Xiaomi Corporation (Xiaomi) of China as a Communist Chinese Military Company (CCMC) pursuant to Executive Order (EO) 13959 and Section 1237 of the National…

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to the Russian Federation’s imprisonment and alleged previous poisoning of opposition figure Aleksey Navalny. These actions follow similar sanctions imposed by the European Union and the United Kingdom. Dozens…