Janet K. Kim


On March 5, 2020, pursuant to Executive Order 13851 of November 27, 2018 and the Nicaragua Human Rights and Anticorruption Act of 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) further escalated sanctions against Nicaragua by naming the Nicaraguan National Police (“NNP”) and three NNP commissioners as Specially Designated Nationals (“SDNs”), citing serious human rights abuses. OFAC previously named other officials of the NNP as SDNs in 2018 and 2019, also citing…

On December 26, 2019, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) published a long-awaited Interim Final Rule (the “Interim Rule”) revising a number of definitions in the International Traffic in Arms Regulations (“ITAR”). While DDTC was accepting comments until January 27, unless a new or revised rule is published, the Interim Rule will go into effect on March 25, 2020. These changes will permit companies storing and transmitting ITAR technical data to benefit from cloud computing and email services that utilize global platforms.

On October 31, 2019, the US State Department strengthened US secondary sanctions targeting Iran under the Iran Freedom and Counter-Proliferation Act of 2012 (“IFCA”) (codified at 22 U.S.C. § 8801 et seq.), which dates back to 2013.  These new IFCA sanctions target the construction sector in Iran and make sanctionable the export to Iran of certain strategic metals.

On September 9, 2019, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published two Frequently Asked Question (“FAQ”) documents (available here and here) on the Huawei Entity List and Temporary General License (“TGL”) and the Huawei TGL Extension (the amended TGL issued on August 21, 2019 is available here).  See our blog post on the extension of the Huawei TGL here.

The key clarifications made by BIS in the two sets of FAQs include the following: