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Alexandre (Alex) Lamy

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On July 2, 2021, the US Government imposed sanctions on several military-affiliated entities and individual senior officials and certain family members in response to the February military coup in Burma (Myanmar). In a statement on the same day, the US State Department said that these “measures further demonstrate that [the US Government] will continue to take additional action against, and impose costs on, the [Burmese] military and its leaders until they reverse course and provide…

On June 9, 2021, the Biden Administration issued Executive Order 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (“EO 14034”). EO 14034 revokes three executive orders issued by the Trump Administration that effectively banned certain Chinese connected software applications (“apps”) from operating in the United States. Although EO 14034 revokes these legal authorities and calls for their implementing rules to be rescinded, EO 14034 signals that the Biden Administration will continue to analyze the national…

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…