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Alexandre (Alex) Lamy

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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 27, 2020, US Customs and Border Protection (“CBP”) published a set of Frequently Asked Questions available here (“FAQ Guidance”) regarding the export of personal protective equipment products (“PPE Products”) covered under the temporary final rule published by the Federal Emergency Management Agency (“FEMA Rule”). Our blog posts on the FEMA Rule, related exemptions, and other developments are available here. The FAQ Guidance provided via a bulletin in CBP’s Cargo Systems Messaging Service includes important information regarding the…

On April 17, 2020, the Federal Emergency Management Agency (“FEMA”) filed a notification of exemptions (the “FEMA Notification”) in the Public Inspection List that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the “FEMA Rule”), which restricts the export from the United States of certain personal protective equipment (“PPE Products”) used in the response to the COVID-19 pandemic. Although the FEMA Notification will not be published in the Federal Register until Tuesday,…

On April 10, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a rule amending the North Korea Sanctions Regulations (“NKSR”). The NKSR amendments implement certain provisions of the North Korea Sanctions and Policy Enhancement Act of 2016 (“NKSPEA”), as amended by the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), and the National Defense Authorization Act for Fiscal Year 2020 (“2020 NDAA”). Our prior blog post on NKSPEA can be found here…