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On January 19, 2021, the U.S. Department of Commerce (“DOC”) issued an interim final rule governing transactions in Information and Communication Technology or Services (“ICTS”)...
not exhaustive or final, but can be revised by DOC as necessary. The scope of prohibited transactions are those between U.S. persons and a “person owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary,” which includes: Any person, wherever located, who acts as an agent, representative, employee, or any other capacity at the order, request, direction, or control of a foreign adversary; A person whose activities are directly or indirectly supervised, directed, controlled, financed or subsidized in whole or in majority part by a foreign adversary; Any pe...