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Ryan Poitras

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On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) strengthened restrictions targeting Burma by adding Burma to the list of countries subject to the Export Administration Regulations’ (“EAR’s”) military-intelligence end-use and end-user controls and controls on certain support activities by US persons (“Interim Final Rule”). These controls were first issued on January 15, 2021 (“January Rule”), and became effective March 16, 2021. Our blog posts on other recent sanctions targeting…

On March 29, 2021, the Commerce Department published an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on potential licensing or other pre-clearance processes for transactions under the regulations that took effect on March 22, 2021 to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (“Executive Order 13873”). Executive Order 13873 authorizes the Commerce Department to block or impose conditions on transactions involving information and communications technology and…

The US Government has imposed a series of sanctions against Myanmar Economic Corporation Limited (“MEC”) and Myanma Economic Holdings Public Company Limited (a.k.a. Myanmar Economic Holding Limited) (“MEHL”), two military-affiliated conglomerates, in response to the February military coup in Burma (Myanmar). The combined restrictions are likely to have a significant impact on business activities in Burma as these conglomerates have substantial interests and joint ventures in several sectors of the Burmese economy, including trading, natural…

On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to remove Sudan’s designation as a State Sponsor of Terrorism (“SST”) (the “Amendments”). The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing Anti-Terrorism (AT) and related controls on Sudan, which had remained in force following the US Government’s revocation of comprehensive sanctions in…