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Daniel Andreeff

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On June 11, 2020, President Trump issued Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (“ICC EO”), which authorizes the imposition of sanctions and visa restrictions on non-US ICC officials in connection with investigations into US or allied government officials or military personnel. The United States is not a party to the Rome Statute, which is the treaty that established the ICC. The President declared a national emergency under…

On May 19, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective on May 15, 2020 amending the Export Administration Regulations’ (“EAR”) General Prohibition Three (the “foreign-produced direct product rule”) and Entity List to impose new controls on the reexport, export from abroad, and transfer (in-country) of certain foreign-produced semiconductor-related items when such items are the direct product of certain designated US technology or software and are destined…

On April 21, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended General License (“GL”) 8E and re-issued it as General Licence No. 8F. GL 8F extends the validity period of certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”) until December 1, 2020, but also narrows the scope of the prior license and provides a new authorization for “wind-down” transactions and activities. Our blog posts describing previous amendments to the general license…

The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on…