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Eunkyung Kim Shin

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In December 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued four General Licenses (“GLs”) (GLs 16, 17, 18, and 19), published seven new Frequently Asked Questions (“FAQs”) (FAQs 949, 950, 951, 952, 953, 954, and 955), and amended three FAQs (FAQs 929, 930, and 931), which address primarily authorized humanitarian activities related to Afghanistan OFAC also issued a Fact Sheet titled “Provision of Humanitarian Assistance to Afghanistan and Support for…

In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…

On November 10, 2021, President Biden signed the Reinforcing Nicaragua’s Adherence to Conditions for Electoral Reform Act (“the RENACER Act”) into law, which calls for increased sanctions against Nicaragua. This followed November 7 elections in Nicaragua that allowed President Daniel Ortega to stay in power for a fourth consecutive term. President Biden had issued a statement referring to the November 7 elections as “a pantomime election that was neither free nor fair.” The RENACER Act…

On September 24, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued two General Licenses—(i) General License 14, “Authorizing Humanitarian Activities in Afghanistan” (“GL 14”), and (ii) General License 15, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan” (“GL 15”)—to “support the continued flow of humanitarian assistance to the people of Afghanistan and other activities that support…