President Trump Amends EO 13959 on “Communist Chinese Military Companies”

There have been several significant developments over the past week in connection with Executive Order (EO) 13959 (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (EO 13959 or Order), dated November 12, 2020.  We have previously addressed developments related to EO 13959 in our posts in November 2020, December 2020, and … Read more

Upcoming Webinar: Sanctions Under the New Administration

The Herbert Smith Freehills global sanctions team invites you to join them for a webinar, to discuss: potential US sanctions implications of the impending change of Administration with respect to Venezuela, China and Russia-related sanctions, as well as the prospects for increased general emphasis on human rights and anti-corruption issues in US sanctions and trade … Read more

New year, new UK sanctions regime

Upon the end of the Brexit transition period at 11pm on 31 December 2020, the UK ceased to implement EU sanctions. UK sanctions are now in force under the UK’s domestic sanctions regime, the framework for which is contained in the Sanctions and Money Laundering Act 2018 (“SAMLA”). The UK has introduced regulations under SAMLA … Read more

NYSE Restores Decision to Delist Subsidiaries of “Communist Chinese Military Companies”

As noted in our previous posts in November and December 2020, the current US Administration has targeted certain alleged “Communist Chinese military companies” (CCMCs) via Executive Order (EO) 13959 (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (EO 13959 or Order), dated November 12, 2020. EO 13959 prohibits US persons from engaging in … Read more

OFAC Publishes Guidance on “Communist Chinese Military Companies”

As noted in our previous post, Executive Order 13959 (“Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies”) (EO 13959 or Order), dated November 12, 2020, targets “Communist Chinese military compan[ies]” (CCMCs) by blocking “any transaction in publicly traded securities, or any securities that are derivative of, or are designed to provide … Read more

The US Government Rescinds Sudan’s State Sponsor of Terrorism Designation

On December 14, the US Department of State removed Sudan from the US State Sponsors of Terrorism List (“SST List”). The State Department explained that, “[t]his achievement was made possible by the efforts of Sudan’s civilian-led transitional government to chart a bold new course away from the legacy of the Bashir regime and, in particular, … Read more

OFAC Introduces Non-SDN Menu-Based Sanctions List

On December 14, OFAC published a new “Non-SDN Menu Based Sanctions List.” The publication is designed to be a reference tool that identifies individuals and entities subject to certain non-blocking menu-based sanctions. OFAC’s publication is available here. “Menu-based” sanctions authorize the relevant agency to select one or more sanctions from a menu of options. OFAC … Read more

EU introduces global human rights sanctions regime

On 7 December 2020, the Council of the EU announced the introduction of a new global human rights sanctions regime, as part the EU Action Plan on Human Rights and Democracy 2020-2024. The new regime introduces a framework to impose a travel ban and asset freeze on individuals and entities identified as responsible for, involved … Read more