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Lise S. Test

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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…

On October 9, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the comment period for the advance notice of proposed rulemaking (ANPRM) on criteria of “foundational technologies.” Comments may now be submitted through November 9, 2020; two weeks after the original deadline of October 26. BIS also clarified it will accept confidential business information from commenters. Filers submitting confidential information should clearly identify the confidential portion at the time of the submission…

On July 31, 2020, the Department of Commerce Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to suspend the availability of all License Exceptions for Hong Kong that provide differential treatment relative to mainland China. Our blog post on prior steps taken to revoke preferential treatment for Hong Kong, including the initial announcement of these suspensions, is available here. The following partial or full License Exceptions are no longer available for…