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US Imposed Sanctions

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On 17 May 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Burmese Sanctions Regulations (“BSR”), 31 C.F.R. Part 537, by issuing new and amending existing general licenses intended to, support trade with Burma, facilitate the movement of goods within Burma, allow most transactions involving designated Burmese financial institutions, and allow certain transactions related to “U.S. Persons” (defined below) residing in Burma. These BSR amendments take effect today (18 May 2016) and are summarized in more detail by OFAC here.

On Thursday, March 24, 2016, the US Commerce Department’s Bureau of Industry and Security (“BIS”) is scheduled to publish a temporary general license in the Federal Register relating to Zhongxing Telecommunications Equipment Corporation (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. (“ZTE Kangxun”). As detailed in a previous post, BIS added these two companies and two affiliated entities (Beijing 8-Star and ZTE Parsian) to the Export Administration Regulations’ (“EAR”) Entity List on March 8, 2016.

On March 8, 2016, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (effective upon publication and with grandfathering limited to items already en route aboard a carrier as of March 8) adding the Chinese multinational telecommunications company Zhongzing Telecommunications Equipment Corporation (“ZTE Corporation”) and three affiliated entities to the Entity List of the Export Administration Regulations (“EAR”). The Entity List identifies parties reasonably believed to be involved in activities contrary to the national security or foreign policy interests of the United States. BIS’s statement on the listing of ZTE Corporation is available here.

On December 7, 2015, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a six-month general license (“General License 20”) to allow certain transactions otherwise prohibited by the Burmese Sanctions Regulations (“BSR”) that are incidental to permissible exports to or from Burma. OFAC’s statement on the issuance of General License 20, which was issued to support US and Burmese exporters and to facilitate trade with Burma, is available here. General License 20 authorizes all transactions until…