Author

Bart M. McMillan

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On September 24, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Final Rule in the Federal Register that amended the Cuban Assets Control Regulations (“CACR”) to further implement the President’s foreign policy to deny the Cuban regime sources of revenue.  Major elements of the changes include: Professional (Including Business) Meetings and Conferences: The Final Rule amends a CACR general license to eliminate the authorization for CACR parties to attend…

The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”). These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC. By way of background, ITAR Section 122.4(b) requires…

On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”)…

On June 5, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published: (1) a final rule adding nine Chinese entities to the Entity List (the “XUAR Designees”), and (2) a final rule adding twenty four entities located in China, Hong Kong, and the Cayman Islands to the Entity List (the “Military Designees”). Both sets of designations were announced by the Commerce Department on May 22, 2020 (see announcements here and here), but…