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Ryan Poitras

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On July 12, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Venezuela General License 40 (“GL 40”), “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” OFAC concurrently issued related FAQs (FAQ 914 and FAQ 915). Our previous blog posts about US sanctions targeting Venezuela are available here. GL 40 authorizes US persons to engage in transactions and activities through July 7, 2022 related to the…

On June 9, 2021, the Biden Administration issued Executive Order 14034, “Protecting Americans’ Sensitive Data from Foreign Adversaries” (“EO 14034”). EO 14034 revokes three executive orders issued by the Trump Administration that effectively banned certain Chinese connected software applications (“apps”) from operating in the United States. Although EO 14034 revokes these legal authorities and calls for their implementing rules to be rescinded, EO 14034 signals that the Biden Administration will continue to analyze the national…

On May 28, 2021, the Biden Administration issued a press release (“Press Release”) confirming the re-imposition of sanctions on certain Belarusian state-owned enterprises (“SOEs”) (presaged by the issuance of wind down Belarus General License 2H on April 19, 2021) and suspending the application of the 2019 US-Belarus Air Services Agreement (“2019 USB Agreement”) in response to the Belarusian government’s apparent forced diversion of a commercial flight to Minsk on May 23. The Press Release also…

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…