On April 27, 2023, the US Department of State (“State”) designated Russia’s Federal Security Service (“FSB”) and Iran’s Islamic Revolutionary Guard Corps Intelligence Organization (“IRGC-IO”) pursuant to Executive Order (“EO”) 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 (“SDN List”). 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 (“Commerce”). The following day a final rule came into effect updating Commerce’s 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 Commerce’s current view of…
On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s 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 Department’s Bureau of Industry and Security (“BIS”) issued a final rule creating a 90-day Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (“EAR”) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and its sixty-eight non-US affiliates, which were added to the BIS Entity List effective May 16, 2019 (the “Entity List designation”). The TGL will be effective through August 19, 2019. Please see our prior blog post here for more information on the Entity List designation.