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Lise S. Test

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On May 18, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 1B, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1B”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. Our blog posts on EO 13959 and OFAC’s prior guidance on the CCMC sanctions program are available here and here. As with the…

On April 19, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) revoked Belarus General License 2G (“GL 2G”), which had generally authorized US Person participation in transactions involving nine Belarusian state-owned entities designated as Specially Designated Nations (“SDNs”), and entities in which they own a 50 percent or greater interest. The revocation of GL 2G effectively strengthens US sanctions against Belarus, and may make it more difficult for US Persons to conduct…

On April 1, 2021, President Biden revoked Executive Order 13928 “Blocking Property of Certain Persons Associated with the International Criminal Court” (the “ICC EO”), which authorized the imposition of sanctions and visa restrictions on non-US ICC officials. The US Treasury Department’s Office of Foreign Assets Control concurrently removed two senior ICC officials from the Specially Designated Nationals and Blocked Persons List (“SDN List”), including Fatou Bensouda, the ICC’s chief prosecutor. The ICC EO was signed…

On March 18, 2021, the US State Department (“State”) published in a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by…