Author

Sylwia A. Lis

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On April 15, 2020, the US Departments of State, Homeland Security, and the Treasury (“Treasury”), and the Federal Bureau of Investigation issued an advisory warning about the cyber threat posed by North Korea, calling particular attention to banks and other financial institutions (“Advisory”). The Advisory (i) highlights North Korea’s malicious cyber activities across the globe, (ii) identifies and recommends measures to counter the cyber threat, including cybersecurity best practices, and (iii) summarizes potential enforcement actions…

On April 28, 2020, the Department of Commerce’s Bureau of Industry and Security (“BIS”) published two new final rules and a proposed rule in the Federal Register amending the Export Administration Regulations (“EAR”) to tighten restrictions on exports of technology to China, Russia, and Venezuela. According to Commerce Secretary Wilbur Ross, these actions are intended to combat efforts by entities in China, Russia, and Venezuela to use certain US technologies obtained through civilian supply chains…

The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on…

On January 6, 2020, the US Department of State’s US Directorate of Defense Trade Controls (“DDTC”) published a set of Frequently Asked Questions (“FAQs”) (available here), which provide long-awaited clarifications regarding the registration and authorization requirements of the International Traffic in Arms Regulations (“ITAR”) applicable to the provision of defense services abroad by natural US persons employed by foreign persons. The main points are summarized below: The FAQs clarify that no registration with DDTC is…