Today, President Biden issued an Executive Order (E.O.) that authorizes new U.S. sanctions on Burma in response to the recent military coup in that country. The E.O. allows the U.S. Office of Foreign Assets Control (OFAC) to impose sanctions on the country’s military leadership and could lead to broader sanctions on government-controlled ministries and companies
BIS Rule Will Impose New Restrictions on “Military-Intelligence” End Users and End Uses in China, Russia, and Venezuela
On January 15, 2021, the Bureau of Industry and Security (BIS) published an Interim Final Rule to implement new end-user and end use controls mandated by the Export Control Reform Act of 2018 (ECRA).
Most notably, the rule adds a new control that will require U.S. persons to obtain a license before “supporting” certain “military-intelligence”
BIS Lifts Anti-Terrorism Export Controls on Sudan
Effective January 14, 2021, the Bureau of Industry and Security (“BIS”) announced amendments to Export Administration Regulations (“EAR”) to implement the rescission of Sudan as a State Sponsor of Terrorism. The U.S. Department of State removed Sudan’s designation effective December 14, 2020.
The changes to the EAR remove export control licensing requirements for many exports
China National Offshore Oil Corporation added to U.S. Entity List
Today, the Bureau of Industry & Security (BIS) added China National Offshore Oil Corporation Ltd. (CNOOC) to the U.S. Entity List. Under the new rule, U.S. and non-U.S. exporters are generally prohibited from transferring items subject to the U.S. Export Administration Regulations (EAR) to CNOOC without first obtaining a U.S. export license. As noted in
Recent OFAC Settlement Highlights Need to Consider IP Address Geolocation Data
On December 30, 2020, the Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with BitGo, Inc. (“BitGo”) for providing digital wallet services to users located in sanctioned jurisdictions, including Crimea, Cuba, Iran, Sudan, and Syria. The case is notable because OFAC makes clear its expectation that companies consider Internet Protocol (“IP”) address geolocation
Commerce Announces New Military End User List, Naming over 100 Chinese and Russian Entities
Today, the Bureau of Industry and Security (BIS) announced that it will create a new “Military End-User List” (MEU List) to help exporters comply with the recently expanded military end-use and end-user restrictions (MEU Rule) that apply to exports of certain items to China, Russia, and Venezuela. The current MEU List includes 102
U.S. Imposes Entity List Restrictions on Large Chinese Semiconductor, Shipbuilding, and Drone Companies
Today, the United States added 60 companies in China and 17 companies located elsewhere to the Commerce Department’s Entity List. Among the Chinese firms targeted are chipmaker Semiconductor Manufacturing International Corporation (SMIC) and ten semiconductor companies related to SMIC, shipbuilder China State Shipbuilding Corporation (CSSC), and drone manufacturer DJI. The move is the latest step
Four Chinese Companies Added to Coming Securities Ban
Yesterday, the Department of Defense (DoD) designated four additional companies as owned or controlled by the Chinese military, expanding the list of “Communist Chinese military companies” (CCMCs) to 35 companies. As previously recounted on this blog, Executive Order 13959 (the Order) will prohibit U.S. persons from purchasing the publicly traded securities of CCMCs once
Chinese Tech Firm Subject to U.S. Sanctions for Supporting Censorship in Venezuela
On November 30, the United States sanctioned China National Electronics Import and Export Corporation (CEIEC) by adding the Chinese technology company to the Specially Designated National (SDN) List. Treasury’s Office of Foreign Assets Control (OFAC) designated the company under Executive Order 13692 for providing goods and services to the Venezuelan government that were used to
New Executive Order Targets Investments in Chinese Companies Linked to the Military
On November 12, 2020, the President issued Executive Order 13959 (the Order) to prohibit U.S. persons from purchasing the publicly traded securities of certain companies that are affiliated with China’s military. While the Order does not come into force until January 11, 2021, U.S. financial services companies and U.S. investors will need to carefully review