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Terence Gilroy

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In parallel with the new advanced computing, semiconductor, and supercomputing rules issued on October 17, 2023 (here), the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Rule”) amending the Export Administration Regulations (“EAR”) to revise the existing Validated End-User (“VEU”) list of items that are eligible to be supplied to Samsung China Semiconductor Co. Ltd. and SK Hynix Semiconductor (China) Ltd., companies headquartered in the Republic of Korea, for their…

On June 28, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the Office of Financial Sanctions Implementation of the HM Treasury (“OFSI”) jointly issued a Humanitarian Assistance and Food Security Fact Sheet (the “Fact Sheet”) to provide additional clarity on US and UK Russia-related sanctions in the context of humanitarian assistance and the export to Russia of agricultural commodities, medicines, and medical devices. The Fact Sheet provides US and…

On March 2, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”), the US Department of Justice (“DOJ”), and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls (“Compliance Note”) warning the public of efforts to evade Russia-related sanctions and export controls via use of third-party intermediaries and transshipment points. To aid the…

Last week, among the flurry of new sanctions announcements marking the one-year anniversary of Russia’s large-scale invasion of Ukraine, the G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.” The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated”…