On February 20, 2025, the US Department of State designated several international cartels and transnational criminal organizations as Foreign Terrorist Organizations (“FTOs”) pursuant to section 219 of the Immigration and Nationality Act and as Specially Designated Global Terrorists (“SDGTs”) pursuant to Executive Order (“EO”) 13224. These parties have been designated for “threaten[ing] the safety of the American people, the security of the United States, and the stability of the international order in the Western Hemisphere,ā…
On January 16, 2025, the US Commerce Departmentās Bureau of Industry and Security (āBISā) published an interim final rule (the “IFR”) revising the Export Administration Regulations (“EAR”) to impose new controls on certain biotechnology equipment and related technology. As stated in the IFR, the new controls are necessary to protect against US national security and foreign policy interests “given the dual-use nature and relevance of specific biotechnology equipment to contribute to the research and development…
On January 2, 2025, the US Commerce Departmentās Bureau of Industry and Security (āBISā) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…
On November 21, 2024, the US Department of the Treasuryās Office of Foreign Assets Control (āOFACā) designated dozens of Russian banks, including Gazprombank and other Russian banks, securities registrars, and finance officials, to the List of Specially Designated Nationals and Blocked Persons (āSDN Listā). The full SDN designation of Gazprombank, the largest remaining Russian bank, is particularly notable given its role in supporting gas flows between Russia and remaining European and other customers. On the…