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Paul Amberg

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On September 9, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “2022 IFR”) revising the Export Administration Regulations (“EAR”) to authorize the release of certain technology and software in the context of “standards-related activity” involving entities listed on the Entity List. Comments on the impact of this action on participation in “standards-related activity” must be submitted to BIS no later than November 8, 2022. By…

On July 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued three Russia-related General Licenses (“GLs”) and issued one new one. OFAC also amended FAQs 967, 1,039, and 1,040, with changes mostly relating to updates made within the GLs. OFAC also issued a new fact sheet on “Russia Sanctions and Agricultural Trade.” GL 6B was amended to broaden the scope of authorized activities in three ways: (i) to broaden…

On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) updating the scope of License Exceptions Authorized Cybersecurity Exports (“ACE”) and Encryption Commodities, Software, and Technology (“ENC”) related to cybersecurity items in response to public comments on the interim final rule related to cybersecurity items published on October 21, 2021. The interim final rule established a new control on certain cybersecurity items for…

Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…