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On June 21, 2021, the Office of Foreign Assets Control (OFAC) designated 16 individuals and five entities in response to the Lukashenko regime’s escalating violence and repression. The persons are all closely associated with Belarusian President Alexander Lukashenko and, according to an OFAC press statement, “have harmed the people of Belarus through their activities…

On June 17, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three general licenses related to the sanctions programs of Iran (General License N), Syria (General License 21) and Venezuela (General License 39), “Authorizing Certain Activities to Respond to the Coronavirus Disease 2019 (COVID-19)…

Key Notes:

  • Proposed rule would allow persons working under a long-term contract to be considered “regular employees” under the International Traffic in Arms Regulations (ITAR) even if they work remotely.
  • Remote work would be permitted so long as people were not working in Belarus, Burma, China, Cuba, Iran, North Korea, Russia, Syria or Venezuela, or

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The State Department’s Directorate of Defense Trade Controls (DDTC) on June 1, 2021 announced that a final rule from January 2020, which moved 3D-printed guns out from control under the International Traffic in Arms Regulations (ITAR) over to the Export Administration Regulations (EAR), is now in effect. See Federal Register notice of January 23, 2020…

On April 12, 2021, the State Department’s Directorate of Defense Trade Controls (DDTC) issued additional guidance regarding changes that have been made to the International Traffic in Arms Regulations (ITAR) pertaining to export of defense articles or services to Russia. The guidance summarizes changes that were implemented on March 18, 2021, when the Departments of…

The U.S. Department of Commerce’s Bureau of Industry & Security (BIS) issued a final rule amending the Export Administration Regulations to eliminate most reporting requirements related to open source encryption software and certain “mass market” encryption items and to revise the Commerce Control List.

Key Notes:

  • BIS issued a final rule eliminating certain reporting requirements

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On April 8, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule adding seven Chinese supercomputing entities to the Entity List for “conducting activities that are contrary to the national security or foreign policy interests of the United States” due to their support of China’s military modernization and “other…

Note: This previously published client update has been revised to provide links to the official notices published by the Departments of Commerce and State on March 18, 2021.

On March 2, 2021, the Departments of Commerce, State and the Treasury imposed sanctions and export restrictions on numerous Russian officials and government entities in response to…