Export Controls & Sanctions

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US Department of State Imposes Visa Restrictions on Chinese Officials for Repression in Xinjiang

On October 8, 2019, the Secretary of State announced visa restrictions on Chinese government and Communist Party officials believed to be responsible for, or complicit in, the detention or abuse of Uighurs, Kazakhs or other members of Muslim minority groups in Xinjiang, China. Family members of named persons may also be subject to these restrictions. The visa restrictions support the Department … Continue Reading

OFAC Enters Settlement With The General Electric Company for Violations of Cuba Sanctions

In early October, OFAC announced a US$2,718,581 settlement with The General Electric Company (GE) of Boston, Massachusetts. GE, on behalf of three GE subsidiaries, Getsco Technical Services Inc., Bentley Nevada and GE Betz (collectively, the “GE Companies”), agreed to settle its potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations (CACR). Specifically, between December 2010 and February … Continue Reading

Trump Administration Authorizes Sanctions on Turkey

Responding to Turkey’s actions in Syria, President Trump issued an Executive Order (EO) blocking property and suspending entry of certain persons contributing to the situation in Syria. Pursuant to the EO, OFAC added three Turkish government officials and two Turkish government agencies, the Ministry of National Defence and the Ministry of Energy and Natural Resources, to the Specially Designated Nationals (SDN) … Continue Reading

US Office of Foreign Assets Control (OFAC) Temporarily Extends Belarus-related General License

On October 22, 2019, OFAC issued General License No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. General License No. 2G replaces General License No. 2F and authorizes transactions with blocked entities by Belerusian Oil Trade House, Belneftekhim,  Belneftekhim USA, Inc., Belshina OAO, … Continue Reading

US Department of Commerce Adds 28 Chinese Organizations to Its Entity List

In response to ongoing human rights violations, BIS announced that it would add 28 Chinese governmental and commercial organizations to the Entity List for engaging in or enabling activities contrary to the foreign policy interests of the US. This action targets those entities implicated in human rights violations and abuses in China’s campaign targeting Uighurs and other predominantly Muslim ethnic minorities … Continue Reading

OFAC Implements Sanctions on Nicaragua

On September 4, 2019, the US Department of the Treasury’s Office of  Foreign Assets Control (OFAC) published in the Federal Register a new final rule on the Nicaragua Sanctions Regulations, 31 C.F.R. Part 582 (Nicaragua Regulations), which implement Executive Order (EO) 13851 of November 27, 2018, “Blocking Property of Certain Persons Contributing to the Situation in Nicaragua”. The Nicaragua Regulations mirror the substance … Continue Reading

Update: Turkey’s Actions Spur Transatlantic Sanctions Response

The Trump Administration issued an Executive Order (EO) on October 14, 2019, that authorized US Department of the Treasury (Treasury) and US Department of State to impose sanctions on various Turkish individuals and entities involved in the conflict in Northern Syria. The same day that the EO was issued, Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and two entities as … Continue Reading

Advice for Chinese Companies: How to Cope with Strengthened US Export Controls and CFIUS – Seminars in Shanghai and Beijing – October 2019

Keep US Open to Chinese Business: 维持一个对华企业开放的美国: How to Cope With Strengthened US Export Controls and CFIUS 应对日趋严格的美国出口管制和CFIUS审查的实务指南 Friday, October 11, 2019 – Shanghai (2019 年10月11日,周五 – 上海) Tuesday, October 15, 2019 – Beijing (2019 年10月15日,周二 – 北京)… Continue Reading

Training Opportunity: Discussion on Tech-centric Anticorruption and Sanctions Compliance – 20 September, London

20 September 2019  9:30 a.m. – 2:30 p.m. BST Register through techUK (favorable registration rate available to members) Register through eventbrite (event open to non-techUK members) Joining forces with techUK, Content Enablers and Dun & Bradstreet, our International Trade Practice is hosting a timely discussion on tailored approaches for UK technology businesses to effectively navigate … Continue Reading

Recent Cuba Travel-related Settlements With OFAC Demonstrate Importance of Robust Sanctions Compliance Program

On June 13, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced settlements with three travel companies – Expedia Group, Inc. (Expedia), Hotelbeds USA, Inc. (Hotelbeds USA) and Cubasphere Inc. (Cubasphere) – for their alleged involvement in booking travel to Cuba or arranging trips for Cuban nationals between 2011 and 2014.… Continue Reading

US Adds Five Chinese Companies to the Department of Commerce Entity List

On June 24, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule designating five entities, all located in China, to the Entity List. The five entities are: Chengdu Haiguang Integrated Circuit – aliases include Hygon and Chengdu Haiguang Jincheng Dianlu Sheji Chengdu Haiguang Microelectronics Technology – aliases include HMC … Continue Reading

Training Material Available: Export Controls and Technology Transfers Conference – June 19-20, 2019 | Washington DC

George Grammas’s presentation on “Strengthening Trade Compliance in Line with Recent Legislative Developments and Impacts to Controls via an Examination of Extraterritorial Applications, Order of Review, and Classification” is now available in our Learning Center, in which you can also find other training resources and information.… Continue Reading

Huawei Motions for Summary Judgement in Complaint Against US Government

On May 28, 2019, Huawei Technologies Co., Ltd., a Chinese telecommunications company, and its US-based affiliate, Huawei Technologies USA, Inc. (collectively “Huawei”), filed a Motion for Summary Judgment. (See Plaintiffs’ Motion for Summary Judgment, Huawei Technologies USA, Inc. et al v. United States of America, et al, No. 4-19-cv-159-ALM (E.D. Tex. filed May 28, 2019) … Continue Reading

US-Russia: Anticorruption, Sanctions, Counter-sanctions and Compliance for Companies Doing Business – Webinar Presentation Material – Russian Counter-sanction Legislation

Russian Counter-sanctions: Bill Introduced to Criminalize Dissemination of Information That May Result in Introduction or Expansion of Sanctions Against Russian Persons Following our recent webinar, our Moscow Team prepared an analysis of a draft Russian legislation that would prohibit media communications that reveal non-compliance with sanctions or facilitate imposition of sanctions and would also impose criminal … Continue Reading

US Commerce Department Offers Huawei and Affiliated Suppliers Interim Reprieve by Granting Temporary General License Until August 2019

On May 22, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule creating a 90-day Temporary General License (TGL) for Huawei Technologies Co., Ltd. (Huawei) and the 68 affiliated Huawei entities (collectively, the “Huawei Listed Companies”) that were added to the … Continue Reading

US Changes Policy on Helms-Burton Act – Litigation Strategy for Companies Active in Cuba

On May 2, the Trump Administration ceased waiving Title III of the Helms-Burton Act, thus allowing US individuals and companies to file lawsuits against companies that are operating in Cuba and “trafficking” in (meaning, using or profiting from) property in Cuba which was confiscated from them by the government of Cuba. (For additional details, read our earlier publication.) The … Continue Reading

Trump Secures US Telecom Supply Chain with Executive Order; Related Huawei Actions

On May 15, 2019, President Donald Trump issued an Executive Order (EO) titled “Securing the Information and Communications Technology and Services Supply Chain.” The long-awaited EO addresses the use in US communications networks of technologies from certain types of foreign companies.… Continue Reading

US Adds Huawei and Affiliates to the Department of Commerce Entity List – What to Expect From the Final Rule

On May 21, 2019 the US Commerce Department, Bureau of Industry and Security (BIS) is expected to publish in the Federal Register a Final Rule designating Huawei Technologies Co., Ltd. (Huawei) and 68 affiliated Huawei entities located in 26 countries (collectively, the “Huawei Listed Companies”) to the Entity List. … Continue Reading
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