Author

Kerry B. Contini

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On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”).  The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies…

On April 17, 2020, the Federal Emergency Management Agency (“FEMA”) filed a notification of exemptions (the “FEMA Notification”) in the Public Inspection List that identifies 10 exemptions from the temporary final rule published on April 10, 2020 (the “FEMA Rule”), which restricts the export from the United States of certain personal protective equipment (“PPE Products”) used in the response to the COVID-19 pandemic. Although the FEMA Notification will not be published in the Federal Register until Tuesday,…

On April 9, 2020, US Customs and Border Protection (“CBP”) issued internal guidance (available here as of April 14, 2020) (“Guidance”) to CBP Field Operations Directors on CBP’s implementation of 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 “FEMA Rule”). Specifically, the Guidance describes which products and shipments are targeted…

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…