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Lise S. Test

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On January 5, 2021, President Trump issued Executive Order 13971 “Addressing the Threat Posed By Applications and Other Software Developed or Controlled By Chinese Companies” (“EO 13971”), which targets certain Chinese connected software applications. Specifically, EO 13971 prohibits transactions by any person, or with respect to any property, subject to the jurisdiction of the United States, with persons that develop or control the following Chinese connected software applications, or with their subsidiaries: Alipay, CamScanner, QQ…

Over the past two weeks, the Office of Foreign Assets Control (“OFAC”) published a series of FAQs related to Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “CCMC EO” or the “EO”). That EO aimed to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases of securities of certain “Communist Chinese military companies.” Our prior blog…

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…