On December 16, 2021, the US Treasury Departmentās Office of Foreign Assets Control (āOFACā) designated eight Chinese tech companies to the Non-SDN Chinese Military-Industrial Complex Companies (āNS-CMICā) list pursuant to Executive Order 13959, as amended by Executive Order 14032, for their alleged involvement in supporting surveillance of ethnic and religious minorities in Xinjiang, China. On the next day, the US Commerce Departmentās Bureau of Industry and Security (āBISā) also added 37 new parties to the…
In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…
The third installment in our Deeper Dive series into the Biden Administration’s supply chain reports has been published to the Baker McKenzie Global Supply Chain Compliance Blog. In this post, the authors discuss the policy recommendations related to possible additional export controls for products in the semiconductor and advanced packaging supply chain.Ā The first two installments of the Deeper Dive series can be found here and here.Ā Ā
On March 2, 2021, the US Government imposed a series of new measures against Russian Government officials and entities in response to the alleged poisoning and subsequent imprisonment of Russian opposition politician Aleksey Navalny. Specifically, the US State Department (“State”) imposed a number of financial sanctions and export restrictions on Russia; the Office of Foreign Assets Control (“OFAC”) within the US Treasury Department designated seven Russian officials to the List of Specially Designated Nationals and…