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Lise S. Test

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On July 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued three Russia-related General Licenses (“GLs”) and issued one new one. OFAC also amended FAQs 967, 1,039, and 1,040, with changes mostly relating to updates made within the GLs. OFAC also issued a new fact sheet on “Russia Sanctions and Agricultural Trade.” GL 6B was amended to broaden the scope of authorized activities in three ways: (i) to broaden…

On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) updating the scope of License Exceptions Authorized Cybersecurity Exports (“ACE”) and Encryption Commodities, Software, and Technology (“ENC”) related to cybersecurity items in response to public comments on the interim final rule related to cybersecurity items published on October 21, 2021. The interim final rule established a new control on certain cybersecurity items for…

On June 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new and amended Frequently Asked Questions (“FAQs “) regarding the Russian investment ban imposed under Executive Orders 14066, 14068, and 14071 (collectively, the “Investment Ban EOs”). Our prior blog posts on these Investment Ban EOs can be found here and here. These new and amended FAQs define the term “new investment” used in the Investment Ban EOs and…

On May 16, 2022, the US Departments of State and Treasury and the Federal Bureau of Investigation (“FBI”) issued a joint advisory alert to the public about attempts by the Democratic People’s Republic of Korea (“DPRK” a.k.a. North Korea) and DPRK information technology (“IT”) workers posing as non-DPRK nationals to obtain employment outside of North Korea. The Advisory provides guidance to help prevent inadvertent recruitment, hiring, and facilitation of North Korean IT workers, as the…