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
Sanctions
President Biden Terminates U.S. Sanctions Related to the International Criminal Court
On April 2, 2021, President Joseph Biden issued an Executive Order terminating a previously declared national emergency and related sanctions against certain persons involved with the International Criminal Court (ICC). In June 2020, President Trump issued Executive Order 13928 declaring a national emergency due to the ICC’s “illegitimate assertions of jurisdiction over personnel of the…
OFAC Sanctions Additional Chinese Officials for Human Rights Abuses in Xinjiang
On March 22, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Chinese government officials for “serious human rights abuses” against ethnic minorities in the Xinjiang Uyghur Autonomous Region of China. In a brief press statement, the Director of OFAC stated, “Chinese authorities will continue to face consequences as long…
Updated: United States Implements Multiple Sanctions and Export Restrictions on Russia
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…
CBP’s Advisory Committee Issues Recommendations on Forced Labor as Priority Trade Issue
The Commercial Customs Operations Advisory Committee (COAC) of U.S. Customs and Border Protection (CBP) has indicated that CBP intends to add forced labor to its list of priority trade issues. The COAC issued draft recommendations on how to “ensure a more holistic U.S. government-wide approach to addressing forced labor.” The COAC Forced Labor Working Group…
State Department Issues Second Hong Kong Autonomy Report
On March 16, 2021, the State Department identified 24 additional persons it determined are contributing to “the failure of the People’s Republic of China (PRC) to meet its obligations under the Sino – British Joint Declaration … or Hong Kong’s Basic Law” and, as a result, the Department of the Treasury has sanctioned these persons.…
Company Designated as a Communist Chinese Military Company Obtains Court Injunction on Investment Ban
On March 12, 2021, the U.S. District Court for the District of Columbia issued a preliminary injunction which prohibits the Department of Defense (DOD) from enforcing its January 2021 designation of Xiaomi Corporation (Xiaomi) of China as a Communist Chinese Military Company (CCMC) pursuant to Executive Order (EO) 13959 and Section 1237 of the National…
United States Implements Multiple Sanctions and Export Restrictions on Russia
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 the Russian Federation’s imprisonment and alleged previous poisoning of opposition figure Aleksey Navalny. These actions follow similar sanctions imposed by the European Union and the United Kingdom. Dozens…
BIS Implements Additional Export Restrictions on Burma
On March 4, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) announced further export restrictions on Burma initially implemented in February 2021. See Update of February 18, 2021. These actions are in response to the coup in Burma on February 1, 2021, in which the military overthrew the democratically elected civilian…
OFAC and BitPay Enter into Settlement Agreement for Apparent Violations Related to Digital Currency Transactions
On February 18, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) entered into a $507, 375 settlement with BitPay, Inc. (“BitPay”) for 2,102 apparent violations of multiple sanctions programs. BitPay, a cryptocurrency company offering payment processing solutions for merchants to accept digital currency as payment for goods and services, agreed to…
