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

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

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

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

On November 19, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the Currency issued a joint fact sheet to provide clarity to banks regarding how to apply a risk-based approach to charities … Read more

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

In series of coordinated actions and announcements during the course of October and November 2020 (the Recent Iran Actions), three US federal agencies—the US Department of State (DOS), the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury, and the US Department of Justice (DOJ)—targeted both Iranian and non-Iranian entities and … Read more