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Paul Amberg

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The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…

On May 27, the US Congress approved the Uyghur Human Rights Policy Act of 2020 (“S. 3744”), a bill which authorizes the imposition of sanctions on persons, including any official of the Chinese government, determined to be responsible for certain human rights violations and abuses committed against Muslim minority groups in China or elsewhere. The bill, which was approved amidst increasing tensions between the United States and China, now goes to the White House where…

On April 21, US Customs and Border Protection (“CBP”) issued guidance via a bulletin in its Cargo Systems Messaging Service (available here) (“Bulletin”) on the new temporary final rule published by the Federal Emergency Management Agency (“FEMA”) imposing export restrictions on certain personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Bulletin details CBP’s implementation of the PPE export restrictions and its process for determining whether an export may be covered by…

On March 31, 2020, the US Government issued a proposed framework for a peaceful democratic transition in Venezuela. The framework outlines 13 steps for a restructured Government of Venezuela (“GOV”) that, if followed, would lead to the lifting of US sanctions on the GOV, Petróleos de Venezuela, S.A. (“PdVSA”), and other GOV officials and agencies. The framework provides a total of 13 actions, including, among others: a full return of, and restoration of all powers…