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Lise S. Test (US)

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Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…

On July 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced certain updates and changes to its Hong Kong-related sanctions program following the expiration of the national emergency declared in Executive Order (“EO”) 13936, The President’s Executive Order on Hong Kong Normalization. Key changes include: What Changed? OFAC explained that the expiration of EO 13936 does not affect the continuing validity of either the HKAA or the Hong Kong…

On July 10, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”), providing enhanced favorable treatment to the United Arab Emirates (“UAE”) under the Export Administration Regulations (“EAR”). BIS indicates the change is a recognition of the UAE’s status as a US Major Defense Partner, its key role in advancing US national security interests including during Operation Epic Fury, its commitment to implementing effective export…

On June 22, 2026, President Trump signed Executive Order 14411, on Ushering in the Next Frontier of Quantum Innovation (the “EO”). The EO establishes a national policy to maintain a strategic technical advantage in quantum information science and technology (QIST) and leads the development of a robust and trusted quantum ecosystem across QIST research, manufacturing, commercialization, and application. Accordingly the focus of much of the EO is directed at accelerating domestic commercialization and research. Additionally,…