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Nicholas F. Coward

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On July 15, 2020, the US Department of State (“State Department”) updated its guidance (“Updated Guidance”) regarding the implementation of Section 232 of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here and our previous blog post on the 2017 State Department guidance on CAATSA Section 232 here). The Updated Guidance expands the scope of CAATSA Section 232 to target certain investments or other activities related to the…

On May 19, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective on May 15, 2020 amending the Export Administration Regulations’ (“EAR”) General Prohibition Three (the “foreign-produced direct product rule”) and Entity List to impose new controls on the reexport, export from abroad, and transfer (in-country) of certain foreign-produced semiconductor-related items when such items are the direct product of certain designated US technology or software and are destined…

On May 12, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced the lifting of US sanctions on Nynas AB (“Nynas”) and the related revocation of General License No. 13E (“Authorizing Certain Activities Involving Nynas AB”) (“GL 13E”). We blogged about last month’s extension of GL 13E here. Nynas and its subsidiaries were previously subject to US sanctions because Nynas was indirectly owned and controlled by Petróleos de Venezuela SA (“PdVSA”) and,…

On April 21, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended General License (“GL”) 8E and re-issued it as General Licence No. 8F. GL 8F extends the validity period of certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) until December 1, 2020, but also narrows the scope of the prior license and provides a new authorization for “wind-down” transactions and activities. Our blog posts describing previous amendments to the general license…