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Alison J. Stafford Powell

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The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (“MEC”) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (“MEHL”), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant impact on business activities in Burma as these conglomerates have substantial interests and joint ventures in several sectors of the Burmese economy, including trading, natural…

On January 27, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. OFAC concurrently published frequently asked questions (“FAQs”) 878 and 879, which clarify OFAC’s previous guidance on subsidiary entities with…

On January 12, 2021, the US Department of Commerce issued a final rule (the “Final Rule”) amending the Export Administration Regulations (“EAR”) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (“UAS”), also known as “drones.” Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum…

On December 22, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) formally added the Central Bank of Syria (“CBOS”) to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) along with certain high-ranking officials in the Syrian government and affiliated entities. Concurrent with OFAC’s designations, the US State Department (“State Department”) designated six Syrian individuals pursuant to Section 2 of Executive Order 13894, “Blocking Property and Suspending Entry of Certain…