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Daniel Andreeff

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On May 9, 2022, the US Department of Commerce issued a Final Rule (the “Final Rule”) expanding the Russian industry sector sanctions to cover additional items subject to the Export Administration Regulations (the “EAR”) beyond restrictions targeting the Russian energy sector. Under the Russia industry sector sanctions, all items identified in Supplement No. 4 to part 746 of the EAR (“Supplement No. 4”) that are subject to the EAR trigger a licensing requirement when they…

On March 2, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued two new Russia-related general licenses, reissued two existing general licenses, and published and updated several frequently asked questions (“FAQs”) clarifying various aspects of the Russia-related sanctions imposed over the past weeks. In addition, on March 3, 2022, OFAC issued another new Russia-related general license and designated additional parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”). We summarize…

On February 2, 2022, the Department of State published a proposed rule that, most significantly, would amend provisions of the International Traffic in Arms Regulations (“ITAR”) affecting how the nationality of foreign persons is determined for purposes of deemed exports/reexports. Specifically, the proposed rule would modify relevant portions of the definitions of export (ITAR §120.17) and reexport (ITAR §120.19) such that only a foreign person’s current citizenship(s) and current permanent residenc(ies) would need be taken…

Baker McKenzie’s Global Supply Chain Compliance Blog published “Commerce Department Issues Notice of Request for Public Comments on Risks in the Semiconductor Supply Chain and Announces Virtual Forum on Risks in the ICT Supply Chain,” which can be viewed here.