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,”…

Baker & McKenzie is hosting two upcoming year-in-review events to review 2014 developments in U.S. export controls and sanctions. These events are sponsored and organized by the Export Controls and Economic Sanctions Committee of the American Bar Association (“ABA”) Section of International Law. 2014 U.S. Export Controls Year In Review The first ABA event on January 22, 2015, will review 2014 developments in U.S. export controls, including the Export Administration Regulations (“EAR”), International Traffic in…

On December 30, 2014, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued long-awaited guidance clarifying that certain lightly processed crude oil are “petroleum products” that may be exported without a specific authorization otherwise required under the Short Supply Controls relating to crude oil and petroleum products in the Export Administration Regulations (“EAR”). BIS in particular posted frequently asked questions and answers (“FAQs”) to its website that, among other things, clarify how BIS…

On December 18, 2014, the President signed into law the Venezuela Defense of Human Rights and Civil Society Act of 2014 (described in our recent post) and Ukraine Freedom Support Act of 2014 (“UFSA”) (described in our recent post). In a statement on the same day, President Obama said that this law “does not signal a change in the Administration’s sanctions policy” and that his “Administration does not intend to impose sanctions under this law,…