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Maria H. van Wagenberg

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On May 18, 2015, the US Commerce Department’s Bureau of Industry and Security (ā€œBISā€) issued additional guidance on due diligence measures that US exporters should take to prevent unauthorized exports to Russia of items (i.e., goods, software, technology) subject to the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (ā€œEARā€).Ā  This Russia-focused guidance supplements existing ā€œKnow Your Customerā€ guidance found in the EAR. In connection with the crisis in the Ukraine that began in…

On April 1, 2015, President Obama issued an Executive Order (the ā€œCyber EOā€) authorizing the US Treasury Department’s Office of Foreign Assets Control (ā€œOFACā€) to designate as Specially Designated Nationals (ā€œSDNsā€) certain persons that have engaged in ā€œsignificant malicious cyber-enabled activities.ā€ Ā No party has yet been designated under the Cyber EO.Ā  OFAC has stated in its Frequently Asked Questions (FAQs) that the Cyber EO is ā€œintended to address situations where, for jurisdictional or other issues,ā€…

The US Commerce Department’s Bureau of Industry and Security (ā€œBISā€) is issuing a final rule amending the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (ā€œEARā€), to impose a license requirement on the export, reexport, or transfer by any person of virtually all ā€œitems subject to the EARā€ to or within the Crimea region of Ukraine.Ā  The final rule will come into effect tomorrow, January 29, 2015, upon publication in the Federal Register.Ā  It…

Effective at 3:30 pm ET today, President Obama issued an Executive Order Ā that (i) imposes comprehensive sanctions on the Crimea region of Ukraine (ā€œCrimeaā€), which has been occupied by Russia since March 2014, and (ii) provides the authority for blocking certain persons in connection with the situation in Crimea .Ā  OFAC’s announcement is available here.Ā  The Executive Order prohibits the following activities: New investment in Crimea by U.S. Persons (i.e., (i) entities organized under US…