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On July 22, 2020, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) adding eleven Chinese entities to the Entity List (the “XUAR Designees”) due to their alleged involvement in human rights abuses including mass arbitrary detention, forced labor, involuntary collection of biometric data, and genetic analyses targeted at Muslim minority groups in the Xinjiang Uyghur Autonomous Region (“XUAR”). The Final Rule also provided modifications and revisions of thirty-seven existing entries on…

The US Treasury Department and the US State Department have announced two new rounds of sanctions against Syria, including the first designations under the recently-enacted Caesar Syria Civilian Protection Act (“Caesar Act”).  The first round, announced on June 17, 2020, resulted in the addition of 39 individuals and entities to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) pursuant Caesar…

On 15 July 2020, the U.S. and Gulf Cooperation Council (“GCC”)-led Terrorist Financing Targeting Center (“TFTC”) designated six targets affiliated with the Islamic State of Iraq and Syria (“ISIS”), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (“ISIS-K”). The entities that were designated are: Al Haram ExchangeTawasul CompanyAl-Khalidi ExchangeNejaat Social Welfare Organization Five of these targets (which includes…

The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This post highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…