On November 18, 2021, President Biden signed Executive Order (“EO”) 14054 which terminates US sanctions related to Burundi by revoking EO 13712 of November 22, 2015.  EO 13712 imposed sanctions related to Burundi due to “the killing of and violence against civilians, unrest, the incitement of imminent violence, and significant political repression” occurring in Burundi at the time and designated several parties as Specially Designated Nationals (“SDNs”).  Our previous blog post on the issuance of EO 13712 can be found here.  In a press release, the State Department acknowledged the changed circumstances in Burundi following elections in 2020 and in particular the reforms being pursued and the progress made by President Ndayishimiye. As a result of EO 14054, the sanctions and visa restrictions imposed on 11 individuals under EO 13712 have been removed.

The authors acknowledge the assistance of Ryan Orange in the preparation of this blog post.

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Paul Amberg is a partner in Baker McKenzie’s Madrid office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.

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Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.