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Kerry B. Contini

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On August 6, 2020, the Federal Emergency Management Agency (“FEMA”) issued a temporary final rule extending and modifying FEMA’s previously imposed restrictions on the export from the United States of certain personal protective equipment (“PPE Products”) used in the response to the COVID-19 pandemic (“Extension Rule”). The original restrictions on exports of PPE Products imposed by FEMA were published on April 10, 2020. The Extension Rule became effective today, August 10, 2020, and will be…

On 15 July 2020, the U.S. and Gulf Cooperation Council (“GCC”)-led Terrorist Financing Targeting Center (“TFTC”) designated six targets affiliated with the Islamic State of Iraq and Syria (“ISIS”), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (“ISIS-K”). The entities that were designated are: Al Haram ExchangeTawasul CompanyAl-Khalidi ExchangeNejaat Social Welfare Organization Five of these targets (which includes…

On July 14, 2020, President Trump issued Executive Order 13936 “The President’s Executive Order on Hong Kong Normalization” (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong to be treated the same as mainland China. It also authorizes sanctions against persons involved in developing, adopting, or implementing China’s Law on Safeguarding National…

On July 17, 2020, the Federal Emergency Management Agency (“FEMA”) published a request for comments on the letter of attestation process in connection with the export restrictions on certain personal protection equipment (“PPE”). These restrictions were imposed earlier this year in response to the COVID-19 pandemic. Our previous blog posts on the FEMA restrictions and their exemptions can be found here and here. FEMA requires that exporters submit a letter of attestation via a document…