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Daniel Andreeff

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The US Commerce Department’s Bureau of Industry and Security (“BIS”) announced that it is issuing a new License Exception MED that in many cases will eliminate BIS licensing requirements for EAR99 medical devices shipped to and within Russia, Belarus, Crimea, Donetsk People’s Republic (“DNR”), and Luhansk People’s Republic (“LNR”). License Exception MED will go into effect on Monday, April 29. License Exception MED will authorize the export, reexport, and in-country transfer of EAR99 medical devices…

On May 4, 2023, the President Biden issued Executive Order 14098 (“EO 14098”) establishing a sanctions authority that authorizes the US Government to imposes sanctions on persons or entities in Sudan in connection with “the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023.” While no sanctions have been imposed under EO 14098 to date, this new Sudan sanctions authority authorizes the US Government to issue asset blocking…

On December 16, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule that would treat two additional types of transactions as activities that are not exports, reexports, retransfers, or temporary imports (“controlled events”) (and, thus, not require authorization) under the International Traffic in Arms Regulations (“ITAR”). The two additional activities that would not constitute controlled events are: Taking defense articles outside a previously approved country by the armed…

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…