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Alison J. Stafford Powell

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On September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same time, the international community has rejected this unilateral US attempt to snapback UN sanctions. To implement the snapback of UN sanctions, on September…

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…

On July 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding eleven Chinese entities to the Entity List (the “XUAR Designees”) due to their alleged involvement in human rights abuses including mass arbitrary detention, forced labor, involuntary collection of biometric data, and genetic analyses targeted at Muslim minority groups in the Xinjiang Uyghur Autonomous Region (“XUAR”). The Final Rule also provided modifications and revisions of thirty-seven existing entries on…

The US Administration has taken a series of actions in recent days to tighten US export controls for Hong Kong and to sanction Chinese government officials in response to the decision of the Chinese Communist Party (“CCP”) to impose a new national security law for Hong Kong. Most significantly, these actions put Hong Kong on a par with China with respect to license exception eligibility under the US Export Administration Regulations (“EAR”) by suspending all…