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…
On Tuesday, April 7, 2020, the Federal Emergency Management Agency (“FEMA”) filed a temporary final rule (“Rule”) in the Public Inspection issue of the Federal Register to establish export restrictions on certain types of personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Rule implemented the order via Presidential Memorandum (“Order”) dated April 3, 2020, in which the President directed the US Department of Homeland Security, of which FEMA…
On April 3, 2020, President Trump issued an order via Presidential Memorandum (“Order”) invoking an obscure authority under Section 101 of the Defense Production Act, 50 U.S.C. § 4501 et seq. (“DPA”), to potentially restrict exports from the United States of personal protective equipment (“PPE”) needed in the response to the COVID-19 crisis. This is in the wake of numerous countries around the world implementing export bans on PPE and other medical supplies (see our previous blog…
On April 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and extended General License No. 13E (“GL 13E”) to continue the validity period for transactions concerning Nynas AB and its subsidiaries (“Nynas”) that otherwise would be prohibited under Executive Order 13850 or Executive Order 13884 given Nynas’s 50% indirect ownership by Petróleos de Venezuela S.A. (“PdVSA”). The authorization was extended through 12:01 am EST on May 14, 2020. In a…