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BIS adds a number of companies to the Entity List, including Iran Air

As of 16 March 2020 Iran Air and a number of other entities were placed on the Bureau of Industry and Security's (BIS) Entity List. Summary - Companies that use Iran Air as transport, particularly companies engaging in...more

BIS revises Country Group designations for Russia and Yemen, imposing additional licensing requirements and removing availability...

On 24 February 2020 the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce published a final rule amending the Export Administration Regulations (EAR) and imposing additional export licensing...more

U.S. imposes strict export controls on certain artificial intelligence software for automating the analysis of geospatial imagery

The U.S. Department of Commerce's Bureau of Industry and Security (BIS) published an interim final rule on 6 January 2020 imposing licensing requirements on certain artificial intelligence software specially designed to...more

The United States Government issues additional Iran sanctions and a new Executive Order targeting the construction, mining,...

On 10 January 2020, in response to missile attacks by the Iranian military targeting two U.S. bases in Iraq, the United States Department of the Treasury, Office of Foreign Assets Control (OFAC) designated a number of senior...more

U.S. Commerce Department issues proposed rule to implement executive order on telecom supply chain

On 26 November 2019 the U.S. Department of Commerce issued a long-awaited proposed rule (or draft regulations) to implement Executive Order 13873, "Securing the Information and Communications Technology and Services Supply...more

OFAC issues general licenses authorizing certain transactions involving the government of Venezuela

On 5 November 2019 the Office of Foreign Assets Control (OFAC) issued two new general licenses authorizing certain transactions involving the government of Venezuela (GOV) and certain individuals affiliated with the GOV,...more

U.S. government announces enhanced due diligence process for humanitarian trade with Iran and identifies Iran as a jurisdiction of...

On 25 October the U.S. Departments of the Treasury and State announced the establishment of a new channel for conducting due diligence on humanitarian trade with Iran. Foreign governments and foreign financial institutions...more

State Department announces additional notification requirements on official meetings and visits by Chinese officials with U.S....

Recent actions by the U.S. Department of State underscore the Trump administration's efforts to use a "whole of government" approach to address perceived national security threats posed by China. While these actions do not...more

State Department signals increased focus on surveillance technology and human rights abuses

On 4 September 2019 the U.S. State Department issued "Draft 'U.S. Government Guidance for the Export of Hardware, Software and Technology with Surveillance Capabilities and/or parts/know-how'" (draft guidance). ...more

New Huawei Entity List designations, TGL extension, exclusions, and certification changes

The U.S. Commerce Department's Bureau of Industry and Security (BIS) is extending the temporary general license (TGL) for Huawei until 18 November 2019, and adding additional Huawei companies to the Entity List....more

U.S. imposes additional sanctions on Russia under Chemical and Biological Weapons Control and Warfare Elimination Act

On 2 August the United States announced that it will impose a second round of sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) (22 U.S.C. § 5601 et...more

U.S. moves towards (but stops short of) complete embargo on Venezuela

On 5 August 2019 the Trump administration issued Executive Order 13884 (the executive order) imposing sweeping sanctions against the government of Venezuela, including its agencies and instrumentalities as well as any...more

Trump administration further tightens U.S. travel restrictions to Cuba

On 4 June 2019 the Trump administration implemented certain regulatory changes first announced on 17 April 2019 by National Security Advisor Ambassador John Bolton in a foreign policy address regarding the Trump...more

U.S. imposes new sanctions targeting state-owned Venezuelan oil company PdVSA in effort to topple Maduro regime

On 28 January 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) designated Petróleos de Venezuela, S.A. (PdVSA) as a Specially Designated National (SDN) for operating in the oil sector of the...more

New export control and CFIUS restrictions on emerging technologies becoming a reality

The Commerce Department is soliciting public input on identification of certain "emerging technologies" for purposes of new export controls and the recently expanded jurisdiction of the Committee on Foreign Investment in the...more

Win some, lose some: U.S. Russia sanctions developments

The past two weeks have entailed a flurry of sanctions developments related to Russia, including the issuance of a new executive order, and the designation of a number of entities by the U.S. Department of the Treasury's...more

Iran sanctions relief: Easy come, easy go…the United States withdraws from Iran nuclear deal and announces intent to re-impose...

Declaring that it is “defective at its core,” on 8 May 2018, President Trump announced that the United States would withdraw from the Iran nuclear deal and begin re-imposing sanctions that were lifted pursuant to U.S....more

In report to Congress, U.S. Administration identifies, but does not sanction, leading Russian oligarchs and senior government...

On Monday, 29 January, the U.S. Treasury Department submitted an unclassified report to Congress concerning significant senior political figures and oligarchs in the Russian Federation and Russian parastatal entities. ...more

Global Magnitsky Act and Magnitsky Act Designations: same old song, or change of tune?

On December 20, 2017, President Trump issued Executive Order 13818 implementing the Global Magnitsky Act, and the Office of Foreign Assets Control (OFAC) issued the first designations responsive to this statute. ...more

U.S. releases public guidance on entities tied to Russian Defense and Intelligence sectors

On 27 October, the U.S. Department of State published guidance with respect to Russia’s Defense and Intelligence sectors under section 231 of the Countering America’s Adversaries The Sanctions Act (CAATSA). Section 231...more

Not out of the woods yet: What the lifting of Sudan sanctions means for businesses and non-profits

Yesterday, on October 12, 2017, the U.S. permanently revoked most sanctions against Sudan. This lifting represents the completion of a process that began in January 2017, and was extended in July 2017. ...more

De-Certification and the Iran Nuclear Deal: The Beginning of the End, or Much Ado about Nothing?

Press reports indicate that President Trump intends to “de-certify” the Iran nuclear deal this week. In practical terms, that means he would refuse to re-certify one or more statutory elements of a law passed by the U.S....more

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