On January 12, 2021, the US Department of Commerce issued a final rule (the âFinal Ruleâ) amending the Export Administration Regulations (âEARâ) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (âUASâ), also known as âdrones.â Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum…
On October 8, 2020, the US Treasury Departmentâs Office of Foreign Assets Control (âOFACâ) identified the Iranian financial sector as subject to Executive Order (âEOâ) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iranâs financial sector, yet many…
On June 5, 2020, the U.S. Treasury Departmentâs Office of Foreign Assets Control (âOFACâ) published four Frequently Asked Questions (the âFAQsâ) regarding Iran-related sanctions under Executive Order 13902 (âEO 13902â). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in âsignificant transactionsâ or providing âmaterial supportâ to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs…
On May 1, 2020, the Trump Administration issued Executive Order 13920 on “Securing the United States Bulk-Power System” (“Bulk-Power System EO”), which aims to prevent “foreign adversaries” from exploiting vulnerabilities in the US bulk-power system in furtherance of US national security. As explained in further detail in the press release concurrently published by the Department of Energy, the Bulk-Power System EO is meant to prohibit certain transactions involving bulk-power system equipment where the Secretary of…