On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,”…
On January 14, 2025, President Biden took action towards rescinding Cuba’s designation as a State Sponsor of Terrorism (“SST”) and to remove restrictions on financial transactions with certain Cuban parties by issuing to Congress a Certification of Rescission of Cuba’s Designation as a State Sponsor of Terrorism (“Certification”) and National Security Memorandum 29 (“NSM-29”) revoking a past National Security Presidential Memorandum related to Cuba that had been issued by then-President Trump in June 2017. President…
On January 2, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…
On December 2, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued long anticipated and extensive new controls to impair China’s indigenous production of advanced semiconductors and other items that can be used in advanced weapon systems, AI, and advanced computing in support of China’s military-civil fusion program. The new rules have a particular focus on the tools used in semiconductor manufacturing and on certain high bandwidth memory (“HBM”), and this…