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Alexandre (Alex) Lamy

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On September 24, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Final Rule in the Federal Register that amended the Cuban Assets Control Regulations (“CACR”) to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.  Major elements of the changes include: Professional (Including Business) Meetings and Conferences: The Final Rule amends a CACR general license to eliminate the authorization for CACR parties to attend…

On August 27, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) adding 24 Chinese state-owned entities to the Entity List (the “SCS Designees”), including several subsidiaries of China Communications Construction Company (“CCCC”), due to their ties to land reclamation efforts involving artificial islands in the South China Sea. In a press statement released with the designations, the Commerce Department cited the role played by the SCS…

On August 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (“DOT”) suspend private charter flights to all Cuban airports.  This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized public charter flights to and from Havana and other private charter flights authorized for limited purposes.  Secretary Pompeo’s statement cites the Administration’s intent to deny…

The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”). These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC. By way of background, ITAR Section 122.4(b) requires…