On April 27, 2023, the US Department of State (āStateā) designated Russiaās Federal Security Service (āFSBā) and Iranās Islamic Revolutionary Guard Corps Intelligence Organization (āIRGC-IOā) pursuant to Executive Order (āEOā) 14078 (Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home), with the result that the IRGC-IO has been added to the Specially Designated Nationals and Blocked Persons List (āSDN Listā). The IRGC as a whole and FSB were previously designated on the…
On October 6, 2022, the Assistant Secretary for Export Enforcement issued a policy aimed at enhancing enforcement of the antiboycott rules administered by the US Department of Commerce (āCommerceā). The following day a final rule came into effect updating Commerceās guidance on charging and penalty determinations related to violations of the antiboycott provisions of the Export Administration Regulations (the “EAR”). The changes are intended to bring penalty determinations in line with Commerceās current view of…
On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the āTreasury Listā). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAEās repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy. In connection with its establishment of full diplomatic ties with Israel last year under the UAE-Israel…
Effective May 20, 2019, the US Commerce Departmentās Bureau of Industry and Security (āBISā) issued a final rule creating a 90-day Temporary General License (āTGLā) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (āEARā) to Chinese-headquartered Huawei Technologies Co. Ltd. (āHuaweiā) and its sixty-eight non-US affiliates, which were added to the BIS Entity List effective May 16, 2019 (the āEntity List designationā). The TGL will be effective through August 19, 2019.Ā Please see our prior blog post here for more information on the Entity List designation.