Author

Lise S. Test

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On November 18, 2021, President Biden signed Executive Order (“EO”) 14054 which terminates US sanctions related to Burundi by revoking EO 13712 of November 22, 2015.  EO 13712 imposed sanctions related to Burundi due to “the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression” occurring in Burundi at the time and designated several parties as Specially Designated Nationals (“SDNs”).  Our previous blog post on the issuance of…

On November 3, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) adding the following four entities to the Department of Commerce Bureau of Industry and Security (“BIS”) Entity List: Candiru (Israel), NSO Group (Israel), Computer Security Initiative Consultancy PTE (Singapore), and Positive Technologies (Russia). The addition of the four entities comes after the October 21, 2021 publication of an interim rule by BIS establishing controls on the…

On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued an updated ransomware advisory (“Updated Advisory”) highlighting the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action. OFAC concurrently designated SUEX OTC, S.R.O. (“SUEX”) as a Specially Designated National (“SDN”), the first…

On August 11, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a joint Fact Sheet: Supporting the Cuban People’s Right to Seek, Receive, and Impart Information through Safe and Secure Access to the Internet (the “Fact Sheet”) and a related press release. The Fact Sheet highlights the most relevant exemptions and authorizations pertinent to supporting the Cuban people through the provision of certain…