On May 18, 2015, the US Commerce Department’s Bureau of Industry and Security (“BIS”) 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. (“EAR”). This Russia-focused guidance supplements existing “Know Your Customer” 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 “Cyber EO”) authorizing the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to designate as Specially Designated Nationals (“SDNs”) certain persons that have engaged in “significant malicious cyber-enabled activities.” No party has yet been designated under the Cyber EO. OFAC has stated in its Frequently Asked Questions (FAQs) that the Cyber EO is “intended to address situations where, for jurisdictional or other issues,”…
The US Commerce Department’s Bureau of Industry and Security (“BIS”) is issuing a final rule amending the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (“EAR”), to impose a license requirement on the export, reexport, or transfer by any person of virtually all “items subject to the EAR” to or within the Crimea region of Ukraine. The final rule will come into effect tomorrow, January 29, 2015, upon publication in the Federal Register. It…
Effective at 3:30 pm ET today, President Obama issued an Executive Order that (i) imposes comprehensive sanctions on the Crimea region of Ukraine (“Crimea”), 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 . OFAC’s announcement is available here. The Executive Order prohibits the following activities: New investment in Crimea by U.S. Persons (i.e., (i) entities organized under US…