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

The US Department of State Re-Designates Cuba as a State Sponsor of Terrorism

On January 11, the US Department of State (“State Department”) re-designated Cuba to the US State Sponsors of Terrorism List (“SST List”) for “repeatedly providing support for acts of international terrorism in granting safe harbor to terrorists.” Notably, the Trump administration announced the decision shortly before the inauguration of President-elect Biden. The decision to re-designate … 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

OFAC Sanctions Chinese Tech Company for Violating Venezuela Sanctions

On November 30, OFAC designated China National Electronics Import and Export Corporation (“CEIEC”) to its Specially Designated Nationals and Blocked Persons list (“SDN List”). The OFAC press release is available here. CEIEC is a Chinese state-owned technology corporation. According to its website, CEIEC claims that it is a “close partner of many foreign government[s], military … Read more