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Sylwia A. Lis

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On August 9, 2023, President Biden issued Executive Order 14105, targeting certain US investments into Chinese companies or Chinese-owned companies engaged in three advanced technology areas (Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, the “EO”). The EO directs the US Department of the Treasury (“Treasury”) to issue regulations that will (1) prohibit certain categories of US outbound investments and (2) require notification of other investments involving the…

On July 19, 2023, the Bureau of Industry and Security (“BIS”) in the US Commerce Department published much-anticipated guidance for license applications involving medical-related items destined to Russia, Belarus, and the Occupied/Covered Regions of Ukraine (Crimea, Donetsk People’s Republic, and Luhansk People’s Republic). The guidance is just over three pages long, and we recommend that companies submitting applications for medical-related items to these destinations review the document in full. While BIS has been communicating many…

On June 1, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added four (4) entities to the Specialty Designated Nationals (“SDN”) List under Executive Order 14098 (“EO 14098”) and issued four general licenses (“GLs”) authorizing certain transactions involving Sudan. For more information on EO 14098, see our previous blog post available here. We summarize the four GLs below that authorize certain activities and transactions involving SDNs designated under EO 14098.…

On April 18, 2023, Matthew S. Axelrod, the Assistant Secretary for Export Enforcement, US Department of Commerce’s Bureau of Industry and Security (“BIS”), issued a memorandum titled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “VSD Policy Memorandum”) to clarify and announce BIS’ policies concerning voluntary self-disclosures (“VSDs”) of Export Administration Regulations (“EAR”) violations and disclosures of possible EAR violations committed by third parties. The VSD Policy Memorandum builds on Assistant Secretary…