On March 2, 2021, the US Government imposed a series of new measures against Russian Government officials and entities in response to the alleged poisoning and subsequent imprisonment of Russian opposition politician Aleksey Navalny. Specifically, the US State Department (“State”) imposed a number of financial sanctions and export restrictions on Russia; the Office of Foreign Assets Control (“OFAC”) within the US Treasury Department designated seven Russian officials to the List of Specially Designated Nationals and…
On September 15, 2020, the Treasury Department published the anticipated final rule modifying the scope of the critical technology filing requirement under the regulations of the Committee on Foreign Investment in the United States (“CFIUS”). The final rule tracks the proposed rule issued on May 21, 2020 in aligning more closely filing requirements for foreign investments with export licensing requirements. Effective October 15, 2020, filings will be mandatory for foreign investments in US critical technology…
The Directorate of Defense Trade Controls (“DDTC”) within the US State Department recently issued a number of announcements regarding submissions related to Mergers, Acquisitions, and Divestitures (“MAD”) of US businesses regulated under the International Traffic in Arms Regulations (“ITAR”). These changes by DDTC were prompted by the COVID-19 crisis and end the need for parties in MAD transactions involving ITAR-regulated entities to submit hard copies to DDTC. By way of background, ITAR Section 122.4(b) requires…
On December 26, 2019, the US State Department’s Directorate of Defense Trade Controls (“DDTC”) published a long-awaited Interim Final Rule (the “Interim Rule”) revising a number of definitions in the International Traffic in Arms Regulations (“ITAR”). While DDTC was accepting comments until January 27, unless a new or revised rule is published, the Interim Rule will go into effect on March 25, 2020. These changes will permit companies storing and transmitting ITAR technical data to benefit from cloud computing and email services that utilize global platforms.