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US Executive Orders

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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 19, 2021, the Trump administration issued Executive Order 13984 (“EO 13984”), “Taking Additional Steps To Address the National Emergency With Respect to Significant Malicious Cyber-Enabled Activities” which amends and expands Executive Order 13694 of April 1, 2015, to detect and deter the use of US infrastructure as a service (“IaaS”) products by foreign malicious cyber actors. Specifically, EO 13984 directs the US Department of Commerce (“Commerce”) to (i) issue regulations to detect and…

On January 27, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 1A, “Authorizing Transactions Involving Securities of Certain Communist Chinese Military Companies,” (“GL 1A”) in relation to OFAC’s Communist Chinese Military Companies (“CCMCs”) sanctions program as implemented pursuant to Executive Order 13959 (“EO 13959”) and amended by Executive Order 13974. OFAC concurrently published frequently asked questions (“FAQs”) 878 and 879, which clarify OFAC’s previous guidance on subsidiary entities with…

On January 19, 2021, the US Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed…