On January 14, 2021, the US Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to remove Sudan’s designation as a State Sponsor of Terrorism (“SST”) (the “Amendments”). The Amendments implement the rescission of Sudan as an SST as announced by the Trump Administration in December 2020 by removing Anti-Terrorism (AT) and related controls on Sudan, which had remained in force following the US Government’s revocation of comprehensive sanctions in…
On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (“EO 14014”), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance of EO 14014, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated thirteen parties on February 10, 2021 and two parties…
On January 15, 2021, the Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (“Rule”) amending various provisions of the Export Administration Regulations (“EAR”) to implement certain provisions of the Export Control Reform Act of 2018 (“ECRA”). Among other things further outlined below, the Rule imposes new restrictions on specific activities of US persons. By way of brief background, the EAR generally controls transactions involving US origin items (i.e., goods, software, technology)…
On December 28, 2020, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (“EAR”) to revise the Country Group designations for Ukraine, Mexico, and Cyprus. BIS has placed these countries’ into more permissive Country Groups due to these countries’ membership in multilateral export control regimes, as well as national security interests and policies compatible with those of the United States. The impact of these…