On December 23, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) by adding a new “Military End User List” (“MEU List”) as supplement no. 7 to part 744 of the EAR. The final rule adds 102 entities to the MEU List, which will consist of Chinese, Russian, and Venezuelan entities that the US Government has determined are “military end users” for purposes…
The Non-SDN Menu-Based Sanctions List On December 14, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new Non-SDN Menu-Based Sanctions List (“NS-MBS List”). The NS-MBS List is not the result of new sanctions but rather is designed as a reference tool to identify persons subject to certain non-blocking menu-based sanctions, including certain sanctions described in Section 235 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), as implemented by…
On October 29, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (the “final rule”) amending the license review policy under the Export Administration Regulations (“EAR”) for items controlled for national security (“NS”) reasons when destined to China, Russia, or Venezuela. The amendments add Venezuela to the list of countries to which the policy applies and modify the policy to replace the reference to military capabilities with a new,…
On October 26, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated additional Iranian individuals, entities and vessels to the Specifically Designated Nationals and Blocked Persons List (the “SDN” List) pursuant to Executive Order 13224 (as amended) (“EO 13224”), a counter-terrorism authority, for their support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”), an entity designated under EO 13224. Among the designated entities are the Iranian Ministry of Petroleum, the…