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Yu (Iris) Zhang

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On October 26, 2021, the Department of Commerce’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments concerning the identification of certain neuro “brain-computer interface” (BCI) technology as an emerging technology and the potential imposition of export controls on such technology. Comments are due no later than December 10, 2021. BCI technology was identified by BIS back in a November 2018 ANPRM as part of a representative…

On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule, effective June 8, amending the Export Administration Regulations (“EAR”) to reflect the formal termination by the United Arab Emirates (“UAE”) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after…

On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued three pandemic-related general licenses (“GLs”) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19…

On April 12, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued four amended Frequently Asked Questions (“FAQs”) related to submissions made pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”), as well as the Sudan Program and Darfur Sanctions. We summarize these FAQs below. FAQs Concerning TSRA FAQs 97 and 98 clarify the process for obtaining a TSRA license, as follows: FAQ 97 provides…