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Orfeh Vahabzadeh

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In parallel with the new advanced computing, semiconductor, and supercomputing rules issued on October 17, 2023 (here), the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Rule”) amending the Export Administration Regulations (“EAR”) to revise the existing Validated End-User (“VEU”) list of items that are eligible to be supplied to Samsung China Semiconductor Co. Ltd. and SK Hynix Semiconductor (China) Ltd., companies headquartered in the Republic of Korea, for their…

On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…

On March 2, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”), the US Department of Justice (“DOJ”), and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls (“Compliance Note”) warning the public of efforts to evade Russia-related sanctions and export controls via use of third-party intermediaries and transshipment points. To aid the…

On October 28, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a first round of FAQs regarding the advanced computing and semiconductor manufacturing Interim Final Rule, published on October 13, 2022 (87 Fed. Reg. 62,186) (the “Rule”) and amending the Export Administration Regulations (“EAR”). The FAQs are available here and the Rule is available here. Our blog post related to the Rule is located here. The FAQs address certain questions around:…