BIS advises financial institutions to guard against EAR violations through: (1) screening against export lists, (2) enhanced due diligence for high-risk transactions, (3) derisking, and (4) reporting and self-disclosing EAR violations. The BIS guidance reiterates FIs’ obligation to file suspicious activity reports (SARs) as directed in three prior FinCEN-BIS alerts.
China Restricts Exports of Rare Earths Processing Tech Author: Hdeel Abdelhady Once again, China appears to take a page from the U.S. export…
MassPoint Principal Hdeel Abdelhady will participate in the American University Law Review Federal Circuit Symposium, as a panelist on international trade and technology.
OFAC issued two general licenses authorizing certain Afghanistan humanitarian aid and activities involving the Taliban or the Haqqani Network. The licenses authorize transactions otherwise prohibited by the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (GTSR); the Foreign Terrorist Organization Sanctions Regulations, 31 C.F.R. part 597 (FTOSR); or, Executive Order 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism,” as amended (EO 13224).
On August 14, President Trump ordered ByteDance to divest its assets and interests in TikTok. What happens if ByteDance does not comply? The question may seem academic, given historical compliance with divestment orders and ByteDance’s talks with U.S. companies about TikTok’s sale. But a recent legal move by China—its expansion of a list of technologies that require government approval for export, including apparently in a sale of TikTok—renders real the issue of non-compliance with the August 14 divestment order, and potentially raises unprecedented issues.
In the second part of her Q&A with Accuity, Hdeel Abdelhady shared her thoughts on the current and potential impacts of the COVID-19 pandemic on global supply chains, sanctions, and financial crime
U.S. Controls Over Foreign Access to and Influence on Technology and Research in 2020: A Quick Guide U.S. companies, academic and research institutions,…
OFAC’s sanctions enforcement against SITA, the Switzerland-based provider of global air transport technology and services, premised U.S. sanctions jurisdiction on the provision of U.S.-origin technology and the involvement in transactions of networking hardware and servers located in the United States.
Perceiving China’s technological ascendance as a threat, the United States has imposed defensive legal measures, including export controls, to curb foreign access to U.S. technology by illicit and lawful means. The approach has bipartisan backing across the U.S. government.