On July 22, 2015 the U.S. Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations, 15 C.F.R. Parts 730-774 (“EAR”), to implement the rescission of Cuba’s designation as a State Sponsor of Terrorism (BIS has also issued FAQs). As discussed in our previous blog posts here and here, the U.S. Secretary of State rescinded the designation of Cuba as a State Sponsor of Terrorism on May 29, 2015, as…
On May 22, 2015, the US Government relaxed certain export and reexport controls imposed under US sanctions targeting the Crimea region of Ukraine (“Crimea”). Specifically, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new General License authorizing the export or reexport from the United States or by US Persons to persons in Crimea of certain services and software incident to the exchange of personal communications over the Internet. In coordination with…
On April 14, 2015, President Obama submitted to the U.S. Congress a report and certification indicating the Administration’s intent to rescind Cuba’s designation as a State Sponsor of Terrorism. The rescission of Cuba’s designation as a State Sponsor of Terrorism will become effective unless Congress enacts a joint resolution prohibiting the proposal within 45 days after receiving the report. The proposal is part of the Obama Administration’s efforts to establish diplomatic relations with Cuba…
On January 30, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three Ukraine-related general licenses authorizing certain transactions relating to Crimea that would otherwise be prohibited under Executive Order 13685. As detailed in our recent post, Executive Order 13685 imposed comprehensive sanctions on the Crimea region of Ukraine and provided the authority for blocking certain persons in connection with the situation in Crimea. Consistent with Executive Order 13685, the US Government…