On July 14, 2020, President Trump issued Executive Order 13936 “The President’s Executive Order on Hong Kong Normalization” (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong to be treated the same as mainland China. It also authorizes sanctions against persons involved in developing, adopting, or implementing China’s Law on Safeguarding National…
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…