Author

Bart M. McMillan

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On July 1, 2021, the Federal Emergency Management Agency (“FEMA”) announced that the temporary final rule that placed export restrictions on certain medical supplies and personal protection equipment products (“PPE Products”) has expired.  There are now no current export restrictions on these items.  The temporary final rule was first published in April 2020 to allocate scarce medical supplies and PPE products for domestic use in response to the COVID-19 pandemic.  Exemptions from export restrictions were published…

On June 8, 2021, President Biden signed Executive Order 14033 “Blocking Property and Suspending Entry Into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans” (“EO 14033”), expanding the sanctions regime related to the Western Balkans. The White House also issued a fact sheet that details the US administration’s policy goals. US State Secretary Antony Blinken also issued a statement emphasizing the role that EO 14033 serves in modernizing…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On March 29, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) implementing changes to the Export Administration Regulations (“EAR”) that were agreed to at the December 2019 Wassenaar Arrangement Plenary meeting. Specifically, the Final Rule modified the reporting and self-classification requirements for exports of most mass-market encryption items and the email notification requirement for exports of publicly available encryption source code and beta test software.…