OFAC Reaches Settlement with Alfa Laval Subsidiaries Over Iran Referral

On July 19, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced that it had entered into settlement agreements with two subsidiaries of Alfa Laval AB, the UAE-based Alfa Laval Middle East Ltd. (“AL Middle East”) and the US-based Alfa Laval Inc. (“AL US”) to settle apparent violations of the Iranian Transactions and … Read more

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

OFAC Issues Sanctions in Response to Belarus’s Forced Diversion of a Ryanair Flight

On June 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated sixteen individuals and five entities pursuant to Executive Order (“E.O.”) 13405 of June 16, 2006, entitled “Blocking Property of Certain Persons Undermining Democratic Processes or Institutions in Belarus.” According to a press release, OFAC designated these individuals and … 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

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

US Treasury publishes new Myanmar sanctions regulations

On Friday 28 May, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued the Burma Sanctions Regulations (the Regulations) in relation to the implementation of Executive Order 14014, “Blocking Property with Respect to the Situation in Burma.” The Regulations, which come into effect on 1 June, 2021, provide a framework, consistent … 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