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US Related Items and Policy

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On June 3, 2015, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) and the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) published two proposed companion rules to revise and harmonize certain definitions in the Export Administration Regulations (“EAR”) and the International Traffic in Arms Regulations (“ITAR”) as part of the U.S. Government’s ongoing export control reform efforts (the “Proposed Rules”) (see BIS’s proposed rule here and DDTC’s proposed rule here). …

On May 18, 2015, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued additional guidance on due diligence measures that US exporters should take to prevent unauthorized exports to Russia of items (i.e., goods, software, technology) subject to the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (“EAR”).  This Russia-focused guidance supplements existing “Know Your Customer” guidance found in the EAR. In connection with the crisis in the Ukraine that began in…

On April 1, 2015, President Obama issued an Executive Order (the “Cyber EO”) authorizing the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) to designate as Specially Designated Nationals (“SDNs”) certain persons that have engaged in “significant malicious cyber-enabled activities.”  No party has yet been designated under the Cyber EO.  OFAC has stated in its Frequently Asked Questions (FAQs) that the Cyber EO is “intended to address situations where, for jurisdictional or other issues,”…