On December 11, 2020, the Treasury Department submitted its first report to Congress under the Hong Kong Autonomy Act, stating that to date it has not identified any foreign financial institutions (FFIs) that have knowingly conducted a significant transaction with an identified foreign person under the Hong Kong Autonomy Act (HKAA). The Department of
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
U.S. Rescinds Sudan’s Designation as State Sponsor of Terrorism
On December 14, 2020, the State Department announced that the United States was rescinding Sudan’s designation as a State Sponsor of Terrorism. The brief statement indicated that this removal “represents a fundamental change in our bilateral relationship toward greater collaboration and support for Sudan’s historic democratic transition. This achievement was made possible by the efforts…
Commerce Modifies Section 232 Steel and Aluminum Exclusion Request Process
In a Federal Register interim rule to be published on December 14, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was revising certain aspects of the process for requesting exclusions from the additional duties and quantitative limitations implemented on imports of aluminum and steel under Section 232 of the…
DDTC Extends Telework Exemption for Regular Employees and Considers Making It Permanent
In a forthcoming Federal Register Notice, the State Department’s Directorate of Defense Trade Controls (DDTC) is announcing that it is extending until June 30, 2021 the temporary exception provision under the International Traffic in Arms Regulations (ITAR) to allow for continued telework operations during the current COVID-19 public health emergency. DDTC announced this extension…
OFAC Updates FAQs to Clarify Scope of Sanctions Targeting Iran’s Construction, Mining, Manufacturing and Textile Sectors
The Office of Foreign Assets Control (OFAC) has revised Iran-related frequently asked questions (FAQs) to clarify that the sanctions authorized against the Iranian construction, mining, manufacturing and textiles sectors, among others, will not target Iranian manufacturers of medicines, medical devices, or products used for sanitation or hygiene or as personal protective equipment, solely for use…
U.S. and Ecuador Update Trade and Investment Council Agreement
On December 8, 2020, the United States and Ecuador signed a new Protocol on Trade Rules and Transparency that updates the U.S.-Ecuador Trade and Investment Council Agreement (TIC Agreement). The Protocol adds four new annexes on (i) Customs Administration and Trade Facilitation, (ii) Good Regulatory Practices, (iii) Anticorruption and (iv) Small and Medium-Sized Enterprises. In…
Additional Chinese Military Companies Listed Under Section 1237 and Subject to Investment Ban
On December 3, 2020, the Department of Defense (DOD) released the names of four additional “Communist Chinese military companies” operating directly or indirectly in the United States in accordance with the statutory requirement of Section 1237 of the National Defense Authorization Act (NDAA) for Fiscal Year 1999, as amended. The companies are:
- China Construction Technology
…
Commerce Terminates Section 232 Investigation of Mobile Crane Imports
On December 4, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was terminating its Section 232 national security investigation into imports of mobile cranes. The announcement notes that petitioner Manitowoc Company, Inc. requested on September 8, 2020, that its petition be withdrawn due to “a changing economic environment due…
OFAC Sanctions China National Electronics Import and Export Corporation (CEIEC)
On November 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned and placed on the Specially Designated Nationals (SDN) List China National Electronics Import and Export Corporation (CEIEC). The Treasury Department indicated in a press release that this designation was due to CEIEC’s support for “the illegitimate Maduro regime’s efforts…
State Department Imposes Export and Other Restrictions on Chinese and Russian Entities for Transfers of Controlled Items to Iran, North Korea and Syria
On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the…
