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Alexandre (Alex) Lamy

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On February 17, the Bureau of Industry and Security (“BIS”) in the US Commerce Department announced that it is expediting the processing of export license applications for items needed to aid survivors of the earthquakes in Türkiye and Syria through NGOs.  While most items subject to the Export Administration Regulations (“EAR”) do not require licenses for export to Türkiye, Syria is subject to comprehensive US export controls and, as such, items subject to the EAR…

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…

On June 17, 2020, the President signed the Uyghur Human Rights Policy Act of 2020 into law. The law authorizes the President to impose sanctions on persons, including Chinese government officials, determined to be responsible for certain human rights violations and abuses committed against Muslim minority groups in China or elsewhere. The law requires the administration to sanction those individuals by blocking their assets and declaring them ineligible for visas or admission to the United…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020, to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive sanctions targeting Syria under…