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US Executive Orders

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On October 28, 2024, the US Treasury Department (“Treasury”) issued a long-anticipated final rule (“Final Rule”)—effective January 2, 2025—implementing a targeted outbound investment compliance regime called for by Executive Order (“EO”) 14105 issued by President Biden on August 9, 2023. The Final Rule applies to investments by, or in some circumstances directed by, US Persons in Chinese businesses involving specified categories of technologies — namely: semiconductors and microelectronics, quantum information technologies and artificial intelligence (AI).…

On October 11, 2024, the Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order 13902 dated January 10, 2020 (“EO 13902”) designating the petroleum and petrochemical sectors of the Iranian economy as subject to US secondary sanctions. This industry sector designation adds to secondary sanctions designations announced in January 2020 under EO 13902 on the Iranian construction, mining, manufacturing, and textile sectors of the Iranian economy as well as…

On June 21, 2024, the US Treasury Department (“Treasury”) issued a much-awaited Notice of Proposed Rulemaking (“NPRM”)—pursuant to Executive Order (“EO”) 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern”—regarding the upcoming outbound investment review regime, which prohibits or, alternatively, requires notification of certain investments into entities linked to China and engaged in subsets of three specified technologies (semiconductors and microelectronics, quantum information technologies,…

On February 1, 2024, President Biden issued Executive Order 14115 (“EO 14115”) targeting persons involved in activities that threaten the peace, security, and stability in the West Bank. Meanwhile, the UK government announced on 12 February 2024 sanctions on “extremist Israeli settlers” who have committed human rights abuses against Palestinian communities. Pursuant to EO 14115, four individuals were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Treasury Department’s…