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US Department of the Treasury

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The Non-SDN Menu-Based Sanctions List On December 14, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new Non-SDN Menu-Based Sanctions List (“NS-MBS List”). The NS-MBS List is not the result of new sanctions but rather is designed as a reference tool to identify persons subject to certain non-blocking menu-based sanctions, including certain sanctions described in Section 235 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), as implemented by…

On November 13, 2020, the Trump Administration issued Executive Order 13959, “Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies” (the “China Securities EO”), which aims to prevent US investors from financing the development of the People’s Republic of China’s military, intelligence, and security capabilities by prohibiting purchases of securities of certain “Communist Chinese military companies.” This development builds on US Government concerns over China’s civil/military fusion and access to US capital…

On September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same time, the international community has rejected this unilateral US attempt to snapback UN sanctions. To implement the snapback of UN sanctions, on September…

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…