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Inessa Owens

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On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act  (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (“PRC”) and foreign financial institutions who engage in significant transactions with such foreign persons.  During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed…

On June 5, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published: (1) a final rule adding nine Chinese entities to the Entity List (the “XUAR Designees”), and (2) a final rule adding twenty four entities located in China, Hong Kong, and the Cayman Islands to the Entity List (the “Military Designees”). Both sets of designations were announced by the Commerce Department on May 22, 2020 (see announcements here and here), but…

As of May 1, the State Department has made a temporary change in the Tier I, Tier II, and new registrant payment guidelines on the Directorate of Defense Trade Controls (“DDTC”) website to reflect certain reduced registration fees to mitigate the economic impact of the COVID-19 pandemic. The DDTC is reducing fees for Tier I and Tier II registrants to $500 (reduced from $2,250 and $2,750, respectively) for registrations whose original expiration date is between…

On April 21, US Customs and Border Protection (“CBP”) issued guidance via a bulletin in its Cargo Systems Messaging Service (available here) (“Bulletin”) on the new temporary final rule published by the Federal Emergency Management Agency (“FEMA”) imposing export restrictions on certain personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Bulletin details CBP’s implementation of the PPE export restrictions and its process for determining whether an export may be covered by…