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Paul Amberg

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On October 17, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released two interim final rules (collectively, the “October 2023 IFRs” available here and here) amending the Export Administration Regulations (the “EAR”) to further strengthen export controls on advanced computing items, semiconductor manufacturing equipment, and items that can support end uses related to the development and production of supercomputers, advanced-node integrated circuits and semiconductor manufacturing equipment. The long-awaited October 2023 IFRs…

On September 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) established a new humanitarian channel (“HC”) in Qatar to facilitate the provision of humanitarian assistance to the Iranian people. The HC is similar to humanitarian channels established under previous administrations and is designed to help the Iranian people gain access to food, agricultural goods, medicine, and medical devices, while ensuring that funds are not misused and is intended…

On August 8, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued the OFAC Compliance Communique: Guidance for the Provision of Humanitarian Assistance to Syria (the “Guidance”). The Guidance responds to specific questions that OFAC received from the non-governmental organization (“NGO”) community and the general public related to the provision of humanitarian assistance to the Syrian people. In addition, OFAC amended Frequently Asked Question 937 (“FAQ 937”) related to the…

On 30 June 2023, the Dutch government announced supplemental controls for exports of certain advanced semiconductor production equipment from the Netherlands. These controls will enter into force on 1 September 2023. The delegated legislation, Regeling geavanceerde productieapparatuur voor halfgeleiders (the “Regulation”), is available here (in Dutch). The Regulation introduces a prior license requirement for exports of designated semiconductor production equipment items from the Netherlands to destinations outside of the European Union. Intra-Union transfers from the…