Author

Alexandre (Alex) Lamy

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On June 3, 2021, President Biden issued Executive Order 14032, “Addressing the Threat from Securities Investments that Finance Certain Companies of the People’s Republic of China” (the “CMIC EO”). This amends and replaces Executive Order 13959 (“EO 13959”) and revokes Executive Order 13974 (“EO 13974”) that restricted investments in certain “Communist Chinese Military Companies” (“CCMCs”). The main changes implemented by the CMIC EO and related public guidance are to (1) change the group of targeted…

On June 1, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published the Burma Sanctions Regulations at 31 C.F.R. Part 525 (the “BSR”) to implement Executive Order 14014, “Blocking Property With Respect to the Situation in Burma” (“EO 14014”). EO 14014 imposed sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government. The BSR do not expand upon the sanctions previously imposed under EO…

On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register to add seven Chinese parties (together, the “Designees”) to the Entity List.  The Final Rule took effect on April 8, 2021.  According to the Final Rule and the Commerce Department’s press release, the Designees were added to the Entity List because they have procured US-origin items for use in building supercomputers…

On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy. In connection with its establishment of full diplomatic ties with Israel last year under the UAE-Israel…