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

OFAC Amends and Reissues Somalia Sanctions Regulations

On April 27, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended and reissued its Somalia sanctions regulations, which include additional interpretive and definitional guidance, general licenses, statements of licensing policy, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections … Read more

SAP SE Settlement With US Federal Agencies Signals Additional Sanctions and Export Controls Compliance Burden

On April 29, 2021, SAP SE (SAP), a leading international provider of enterprise application software based in Germany, entered into settlements and a non-prosecution agreement (collectively, the SAP settlements) with US federal agencies for alleged violations of US sanctions and US export controls with respect to Iran.   SAP entered into a non-prosecution agreement with the … Read more

UK Introduces Global Anti-Corruption Sanctions

On 26 April 2021, the United Kingdom introduced new unilateral sanctions against 22 individuals accused of involvement in significant corruption cases in Russia, South Africa, South Sudan and throughout Latin America. The Global Anti-Corruption Sanctions Regulations 2021 (the “Anti-Corruption Regulations”), made pursuant to the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) (our full briefing on SAMLA is available here), are … Read more

OFAC Clarifies That NGOs and Foreign Financial Institutions Do Not Risk Exposure to US Secondary Sanctions by Providing Humanitarian Assistance to Syria

On April 5, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published two new Frequently Asked Questions (“FAQs”) related to Syria. Generally, OFAC issues public guidance related to its sanctions programs in the form of FAQs published on its website. FAQ 884 clarifies that, with respect to non-US persons, OFAC … Read more