Nicholas F. Coward, Meghan Hamilton, Yu (Iris) Zhang (China), Author at Global Sanctions and Export Controls Blog

BIS Amends the EAR to Enhance Certain End-Use and End-User Controls as well as Controls on Certain Activities of US Persons

February 16, 2021 By Nicholas F. Coward, Meghan Hamilton and Yu (Iris) Zhang (China) 7 Mins Read

On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (“EAR”) to implement certain provisions of the Export Control Reform Act of 2018 (“ECRA”). Among other things further outlined below, the Rule imposes new restrictions on specific activities of US persons. By way of brief background, the EAR generally controls transactions involving US origin items (i.e., goods, software, technology)…

Department of Energy Issues Prohibition Order Securing Critical Defense Facilities

January 26, 2021 By Nicholas F. Coward, Alexandre (Alex) Lamy (USA), Ryan Poitras and Rod Hunter (USA) 5 Mins Read

On December 17, 2020, the US Department of Energy (“DOE”) issued a “Prohibition Order Securing Critical Defense Facilities“ (the “Prohibition Order”) pursuant to authority granted to the Secretary of Energy by Executive Order 13920 (the “BPS EO“). As of January 16, 2021, the Prohibition Order prohibits certain electric utilities that serve certain defense facilities from acquiring, importing, transferring, or installing identified bulk-power system (“BPS”) equipment and related software produced or supplied by entities subject to…

OFAC Extends Venezuela-Related General License Authorizing Wind-Down Transactions

November 24, 2020 By Nicholas F. Coward and Meghan Hamilton 2 Mins Read

On November 17, 2020, the US Treasury Department’s Office of Foreign Asset Control (“OFAC”) amended General License (“GL”) 8F and re-issued it as General License 8G. GL 8G extends the validity period of certain limited maintenance and wind-down transactions and activities involving Petróleos de Venezuela S.A. (“PdVSA”) until June 3, 2021. Our blog posts describing previous amendments to the general license are available here, here, here, and here. Specifically, GL 8G extends the validity period of the authorization…

First Designations Under the Caesar Syria Civilian Protection Act Target the Syrian Government

August 11, 2020 By Nicholas F. Coward, Samir Safar-Aly (UAE), Inessa Owens and Maria Sergeyeva 6 Mins Read

The US Treasury Department and the US State Department have announced two new rounds of sanctions against Syria, including the first designations under the recently-enacted Caesar Syria Civilian Protection Act (“Caesar Act”). The first round, announced on June 17, 2020, resulted in the addition of 39 individuals and entities to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant Caesar…