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Global Trade & Sanctions Law

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U.S. Commerce Department Publishes Lists of Military End Users in China and Russia Subject to Export License Requirements

On December 21, the Bureau of Industry and Security (BIS) published a Military End User (MEU) list to further implement the military end user/end use (MEU) rule defined in Section 744.21 of the Export Administration Regulations (EAR). An EAR license is required to export or reexport to the listed entities…

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New U.S. Sanctions Target Turkey’s Defense Sector

On December 14, 2020, the U.S. Department of State initiated a series of sanctions pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA) that target the Turkish Presidency of Defense Industries (SSB). The sanctions deny new U.S. export licenses to SSB and limit the SSB’s access…

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Latest Interim Final Rule Introduces Additional Changes to the Section 232 Exclusion Process

On December 14, 2020 the Bureau of Industry and Security (BIS) published an interim final rule (Interim Rule) making changes to the process for seeking exclusions from tariffs imposed on steel and aluminum imports under section 232 of the Trade Expansion Act of 1962 (section 232). The current rule is…

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The EU’s Global Human Rights Sanctions Regime Comes into Force

The EU’s new global human rights sanctions regime came into force on December 8. Council Regulation (EU) 2020/1998 provides for the freezing of funds and economic resources and travel bans on those responsible for or involved in serious human rights violations and abuses worldwide. Individuals and entities who provide financial,…

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U.S. Expands WROs in Xinjiang, Targeting Major Cotton Producer with Implications for Global Supply Chains

On December 2, 2020, U.S. Customs and Border Protection (CBP) issued an import detention or Withhold Release Order (WRO) against cotton produced by Xinjiang Production and Construction Corps (XPCC) based on information that reasonably indicated XPCC used forced labor within its cotton supply chains. This action comes after CBP issued…

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China Tensions Persevere: Trump Issues Executive Order Prohibiting U.S. Investments in Chinese Companies

On November 12, 2020, President Trump issued an Executive Order (E.O.) prohibiting U.S. persons from engaging in any transaction (defined as a “purchase for value”) of publicly traded securities, or transacting in financial products that are derivative of, or provide investment exposure to, securities of designated Communist Chinese military companies…

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U.S. Government Issues Human Rights Policy for Export Licensing and Guidance to Prevent Misuse of Surveillance Tools

Over the course of the Obama and Trump administrations, U.S. officials have found new ways to incorporate human rights concerns into sanctions and export control policies.  Recent announcements by the Commerce and State Departments address how, by the U.S. government in its licensing approvals, and private companies in their foreign-sales…

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U.S. Steps Up Pressure on Iran with Sanctions on Additional Financial Institutions and Continuation of Arms Embargo

Continuing its “maximum pressure” campaign against Iran, the United States has (a) ratcheted up sanctions under Executive Orders that provide for the imposition of secondary sanctions on non-U.S. companies that engage in transactions with Iranian financial institutions, and (b) authorized the imposition of secondary sanctions on non-U.S. companies that engage…

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U.S. Commerce Department Implements Multilateral Controls on Six Emerging Technologies

On October 5, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule that imposes new multilateral controls on six “emerging technologies,” agreed during the December 2019 plenary meeting of the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar…

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World Trade Organization Panel Finds Section 301 Tariffs on Chinese Products Violate WTO Rules, but Decision Unlikely to Have Impact on Tariffs

On September 15, 2020, a World Trade Organization (“WTO”) panel found that the Trump Administration’s unilateral tariffs imposed on Chinese products violated WTO rules regarding nondiscrimination and import tariff rates agreed to by the United States.  The dispute concerned China’s challenge to the Trump Administration’s tariffs imposed pursuant to the…