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Bart M. McMillan

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On February 23, 2022, as “another piece of [the US government’s] initial tranche of sanctions in response to Russia’s actions in Ukraine,” the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated Nord Stream 2 AG, the Swiss company in charge of building Russia’s Nord Stream 2 gas pipeline, and its German chief executive officer, Matthias Warnig, to OFAC’s List of Specially Designated Nationals and Blocked Persons. The sanctions on Nord Stream 2 follow…

On December 15, 2021, President Biden issued Executive Order 14059, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade” (“EO 14059”) aimed at addressing the trafficking of illicit drugs, including the illicit production, global sale and widespread distribution of drugs, in the United States. A press release issued by the Treasury Department explained that the additional authority under EO 14059 builds on the Treasury’s previous sanctions authorities, i.e., in Executive Order 12978…

On November 26, 2021, the Commerce Department of Commerce published a Proposed Rule that would amend its Interim Final Rule on Securing the Information and Communications Technology and Services Supply Chain (“ICTS Regulations”) to specifically address connected software applications. The Proposed Rule would make changes prompted by Executive Order 14034 (“EO 14034”) to the ICTS Regulations.  We previously blogged about the ICTS Regulations here, here, and here.  The Commerce Department is seeking public comments on…

On November 1, 2021, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a final rule amending entries for Ethiopia and Eritrea in the International Traffic in Arms Regulations (“ITAR”). These changes supplement the sanctions imposed on both countries under Executive Order 14046, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia,” which was signed by President Biden in September 2021. Our previous blog post…