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Lise S. Test

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On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule, effective June 8, amending the Export Administration Regulations (“EAR”) to reflect the formal termination by the United Arab Emirates (“UAE”) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after…

On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three pandemic-related general licenses (“GLs”) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19…

On May 18, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 1B, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1B”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. Our blog posts on EO 13959 and OFAC’s prior guidance on the CCMC sanctions program are available here and here. As with the…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…