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Lise S. Test

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On December 7, 2023, the United States Commerce Department’s Bureau of Industry and Security (“BIS”) issued three new rules as a broad effort to ease export control requirements under the Export Administration Regulations (“EAR”) for key allied and partner countries. These rules were enacted in order to reduce the licensing requirement to export, reexport, and transfer US goods, software, and technology to and between allies and partners of the United States. The new rules are…

On October 31, 2023, the US, UK, and Canadian governments imposed further coordinated sanctions against Myanmar (Burma) through designations of individuals and entities associated with Myanmar’s military regime and a US prohibition on the provision of financial services to Myanma Oil and Gas Enterprise (“MOGE”). The measures aim to prevent the Burmese military from obtaining access to arms and other supplies and are part of an effort to unify sanctions measures on Myanmar across the…

On October 17, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released two interim final rules (collectively, the “October 2023 IFRs” available here and here) amending the Export Administration Regulations (the “EAR”) to further strengthen export controls on advanced computing items, semiconductor manufacturing equipment, and items that can support end uses related to the development and production of supercomputers, advanced-node integrated circuits and semiconductor manufacturing equipment. The long-awaited October 2023 IFRs…

On September 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) established a new humanitarian channel (“HC”) in Qatar to facilitate the provision of humanitarian assistance to the Iranian people. The HC is similar to humanitarian channels established under previous administrations and is designed to help the Iranian people gain access to food, agricultural goods, medicine, and medical devices, while ensuring that funds are not misused and is intended…