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Terence Gilroy

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On October 9, the Department of Commerce’s Bureau of Industry and Security (BIS) extended the comment period for the advance notice of proposed rulemaking (ANPRM) on criteria of “foundational technologies.” Comments may now be submitted through November 9, 2020; two weeks after the original deadline of October 26. BIS also clarified it will accept confidential business information from commenters. Filers submitting confidential information should clearly identify the confidential portion at the time of the submission…

On August 27, 2020 the Department of Commerce’s Bureau of Industry and Security (“BIS”) published a long-awaited advance notice of proposed rulemaking (“ANPRM”) seeking public comment on criteria for identifying “foundational technologies” that are essential to US national security with a view to imposing export controls on such uncontrolled technologies. BIS will use the public comments during the interagency process aimed at developing new export controls on foundational technologies. After the interagency process is finalized, BIS will…

On July 14, 2020, President Trump signed into law the Hong Kong Autonomy Act  (“HKAA”) providing for the imposition of sanctions on foreign persons who materially contribute to the undermining of Hong Kong’s autonomy by the Government of the People’s Republic of China (“PRC”) and foreign financial institutions who engage in significant transactions with such foreign persons.  During a press conference announcing the signing of the HKAA, President Trump also indicated that he had signed…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020, to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive sanctions targeting Syria under…