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US State Dept

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On December 9, 2021, the US Departments of State and Commerce amended their regulations to strengthen US export controls targeting Cambodia. According to the Federal Register notices announcing these final rules, these enhanced export control measures were adopted in response to the expanded Chinese military presence in Cambodia, as well as the corruption and human rights abuses allegedly committed by the Cambodian Government. This action builds on various public statements from the US Government this…

In November 2021, the State Department’s Directorate of Defense Trade Controls (“DDTC”) issued new and updated FAQs on violations, disclosures, debarments, rescissions, and reinstatements under the International Traffic in Arms Regulations (“ITAR”). The FAQs mostly reiterate and further clarify past guidance from DDTC on related matters. Key issues are summarized below. For further details, we recommend visiting the DDTC website (here and here) for the full texts of the FAQs. Whether disclosure is required: A…

On September 17, 2021, President Biden signed Executive Order 14046, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”) aimed at addressing the widespread humanitarian conflict in northern Ethiopia. Both the White House and Secretary of State Antony J. Blinken also released statements found here and here, calling for ceasefire negotiations to begin to find a political solution to the ongoing conflict in the region and…

On March 18, 2021, the US State Department (“State”) published in a Federal Register notice that formally outlines the various US export controls targeting Russia that will be strengthened pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”) as a result of State’s determination that the Russian Government had used a chemical weapon against its own nationals in violation of international law. These measures were previously announced by…