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…
On March 29, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) implementing changes to the Export Administration Regulations (“EAR”) that were agreed to at the December 2019 Wassenaar Arrangement Plenary meeting. Specifically, the Final Rule modified the reporting and self-classification requirements for exports of most mass-market encryption items and the email notification requirement for exports of publicly available encryption source code and beta test software.…
On April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) in the Federal Register to add seven Chinese parties (together, the “Designees”) to the Entity List. The Final Rule took effect on April 8, 2021. According to the Final Rule and the Commerce Department’s press release, the Designees were added to the Entity List because they have procured US-origin items for use in building supercomputers…