Kerry B. Contini


On Tuesday, April 7, 2020, the Federal Emergency Management Agency (“FEMA”) filed a temporary final rule (“Rule”) in the Public Inspection issue of the Federal Register to establish export restrictions on certain types of personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Rule implemented the order via Presidential Memorandum (“Order”) dated April 3, 2020, in which the President directed the US Department of Homeland Security, of which FEMA…

On April 3, 2020, President Trump issued an order via Presidential Memorandum (“Order”) invoking an obscure authority under Section 101 of the Defense Production Act, 50 U.S.C. § 4501 et seq. (“DPA”), to potentially restrict exports from the United States of personal protective equipment (“PPE”) needed in the response to the COVID-19 crisis. This is in the wake of numerous countries around the world implementing export bans on PPE and other medical supplies (see our previous blog…

On March 20, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) extended the expiration dates of two general licenses related to GAZ Group (“GAZ”), which was designated as an SDN on April 6, 2018 for being owned or controlled by Oleg Deripaska. Please see our blog post regarding this designation here, and our blog about the previous extension of these general licenses here. At the same time, OFAC expanded one of the…

On January 10, 2020, the US Department of
Transportation (“DOT”) issued an order
imposing new restrictions on public charter flights from the United States to
Cuba. While certain US
restrictions on Cuba, including for travel, were relaxed under President Obama,
the Trump Administration has gradually rolled back some of these changes and
further tightened US travel restrictions vis-à-vis Cuba.