Author

Lise S. Test

Browsing

On May 19, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule effective on May 15, 2020 amending the Export Administration Regulations’ (“EAR”) General Prohibition Three (the “foreign-produced direct product rule”) and Entity List to impose new controls on the reexport, export from abroad, and transfer (in-country) of certain foreign-produced semiconductor-related items when such items are the direct product of certain designated US technology or software and are destined…

On April 28, 2020, the Department of Commerce’s Bureau of Industry and Security (“BIS”) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (“EAR”) to tighten restrictions on exports of technology to China, Russia, and Venezuela. According to Commerce Secretary Wilbur Ross, these actions are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains…

On April 16, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Fact Sheet providing a helpful consolidated summary of the various existing exemptions, exceptions, and authorizations relating to the provision of humanitarian assistance that are available under certain U.S. sanctions programs to leverage in response to the COVID-19 pandemic. Separately, on April 20, 2020, OFAC issued a notice encouraging the prompt communication to OFAC of concerns over potential delays in…

On March 31, 2020, the US Government issued a proposed framework for a peaceful democratic transition in Venezuela. The framework outlines 13 steps for a restructured Government of Venezuela (“GOV”) that, if followed, would lead to the lifting of US sanctions on the GOV, Petróleos de Venezuela, S.A. (“PdVSA”), and other GOV officials and agencies. The framework provides a total of 13 actions, including, among others: a full return of, and restoration of all powers…