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Eunkyung Kim Shin

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On October 1, 2020, the US Department of the Treasury (“Treasury”) issued a pair of advisories to alert companies about risks associated with ransomware scams and attacks. Ransomware is malicious software designed to block access to a computer system or data, often by encrypting data or programs on information technology systems to extort ransom payments from victims in exchange for decrypting the information and restoring victims’ access to their systems or data. The advisories suggest that…

On September 1, 2020, the US Department of State’s Bureau of International Security and Nonproliferation, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Department of Commerce’s Bureau of Industry and Security issued a joint advisory on North Korea’s ballistic missile procurement activities (“Advisory”). The Advisory, among other things, identifies key participants of North Korea’s ballistic missile procurement and their deceptive tactics and key items, including materials and equipment,…

On August 17, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) (i) expanding the Export Administration Regulations (“EAR”) General Prohibition Three (the foreign-produced direct product rule, or the “FPDP Rule”) to further restrict Huawei Technologies Co. Ltd. and its affiliates designated on the BIS Entity List (collectively, “Huawei”) from acquiring foreign-produced semiconductors that are the direct product of certain US software and technology, (ii) removing the…

On July 30, 2020, the US Department of State (“State Department”) expanded secondary sanctions targeting Iran’s nuclear, military, and ballistic missile programs under the Section 1245 of the Iranian Freedom and Counter-Proliferation Act of 2012 (“IFCA”) by including 22 specific metals used in connections with such programs in Iran.  Sanctions may be imposed on persons who knowingly transfer these 22 materials, in addition to the 4 materials already determined by the State Department in October…