Biden Administration Adds 34 Entities to BIS Entity List

On July 12, 2021, the Commerce Department’s Bureau of Industry and Security (BIS) published a Federal Register notice amending the Export Administration Regulations (EAR) by adding 34 entities to the BIS Entity List under 43 entries. The Entity List prohibits US companies from exporting or transferring US products and technology to listed entities without a … Read more

President Biden Revokes TikTok and WeChat Bans

On June 9, 2021, President Biden issued Executive Order (“EO”) 14034, revoking three Trump Administration Executive Orders which had banned transactions involving Chinese-owned apps on national security grounds (the “Revoked Executive Orders”). Despite revoking the bans, EO 14034 acknowledged concerns about software applications controlled by a “foreign adversary” and directed federal agencies to investigate and … Read more

China enacts Anti-Foreign Sanctions Law

On 10 June 2021, the Standing Committee of the National People’s Congress of the PRC enacted the Anti-Foreign Sanctions Law (AFSL), which took effect on the same date. The AFSL follows previous measures taken by the PRC government, including the sanctions announced by the PRC Ministry of Foreign Affairs (MOFA) against foreign individuals and organisations, … Read more

Biden Administration Replaces “Communist Chinese Military Company” Sanctions with “Chinese Military-Industrial Complex” Sanctions

Over the past few days, the US government has issued additional guidance and substantially revised prior guidance related to its sanctions against certain Chinese companies. As discussed in our previous post, Executive Order (“EO“) 13959, dated November 12, 2020, targets “Communist Chinese Military Companies” (“CCMC“) by prohibiting “any transaction in publicly traded securities, or any securities … Read more

OFAC Sanctions Myanmar’s State Administrative Council and Associated Individuals

On May 17, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions designations of the State Administration Council (“SAC”) and sixteen individuals associated with the SAC. The SAC is the senior leadership body that was created by Myanmar’s military government following the coup on February 2, 2021. The SAC … Read more

US Court Temporarily Enjoins the Enforcement of Prohibitions Related to Luokung Technology Corp.’s Designation as a Communist Chinese Military Company

On May 6, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published public guidance related to software firm, Luokung Technology Corp., which was previously designated as a Communist Chinese military company (“CCMC”), pursuant to Executive Order (“EO”) 13959. OFAC explained that the prohibitions in EO 13959 do not currently apply … Read more

OFAC Sanctions Key State-Owned Timber and Pearl Enterprises in Myanmar

On April 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated two state-owned enterprises, Myanma Timber Enterprise (“MTE”) and Myanmar Pearl Enterprise (“MPE”). MTE and MPE were designated pursuant to Executive Order 14014, “Blocking Property With Respect to the Situation in Burma [also known as ‘Myanmar’],” for being a … Read more

Biden Lifts ICC Sanctions, US Moves Closer to Iran Deal

The Biden Administration has announced several significant decisions over the past few days. On April 1, President Biden signed Executive Order 14022 (the “EO 14022”), terminating the national emergency declared in Executive Order 13928, dated on June 11, 2020 (“EO 13928”). EO 14022 reverses EO 13928, which blocked the property of certain persons associated with … Read more