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Iris Zhang

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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 13, 2020, US Secretary of State Mike Pompeo issued a statement requesting that the US Department of Transportation (“DOT”) suspend private charter flights to all Cuban airports.  This action will suspend all charter flights between the United States and Cuba over which the DOT exercises jurisdiction, except for authorized public charter flights to and from Havana and other private charter flights authorized for limited purposes.  Secretary Pompeo’s statement cites the Administration’s intent to deny…

The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”). These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC. By way of background, ITAR Section 122.4(b) requires…

On July 16, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and extended two Ukraine-related general licenses related to GAZ Group (“GAZ”). Notably, General License No. 15I (“GL 15I”), issued to replace General License 15H, authorizes a wider range of activities related to the “the manufacture and sale of existing and new models of vehicles, their components, and spare parts” produced by GAZ. By way of background, GAZ was…