On December 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Chinese tech companies to the Non-SDN Chinese Military-Industrial Complex Companies (“NS-CMIC”) list pursuant to Executive Order 13959, as amended by Executive Order 14032, for their alleged involvement in supporting surveillance of ethnic and religious minorities in Xinjiang, China. On the next day, the US Commerce Department’s Bureau of Industry and Security (“BIS”) also added 37 new parties to the…
In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…
On November 3, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) adding the following four entities to the Department of Commerce Bureau of Industry and Security (“BIS”) Entity List: Candiru (Israel), NSO Group (Israel), Computer Security Initiative Consultancy PTE (Singapore), and Positive Technologies (Russia). The addition of the four entities comes after the October 21, 2021 publication of an interim rule by BIS establishing controls on the…
Baker McKenzie’s Global Supply Chain Compliance Blog published “Commerce Department Issues Notice of Request for Public Comments on Risks in the Semiconductor Supply Chain and Announces Virtual Forum on Risks in the ICT Supply Chain,” which can be viewed here.