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Taylor Parker

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On December 15, 2021, President Biden issued Executive Order 14059, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade” (“EO 14059”) aimed at addressing the trafficking of illicit drugs, including the illicit production, global sale and widespread distribution of drugs, in the United States. A press release issued by the Treasury Department explained that the additional authority under EO 14059 builds on the Treasury’s previous sanctions authorities, i.e., in Executive Order 12978…

In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…

On November 3, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) adding the following four entities to the Department of Commerce Bureau of Industry and Security (“BIS”) Entity List: Candiru (Israel), NSO Group (Israel), Computer Security Initiative Consultancy PTE (Singapore), and Positive Technologies (Russia). The addition of the four entities comes after the October 21, 2021 publication of an interim rule by BIS establishing controls on the…