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Sleeper Trump Rule on 'Military-Intelligence End Uses or Users' Goes Into Effect | Arent Fox

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Companies should be prepared to conduct additional due diligence for any transactions involving entities in the countries enumerated in this rule.

In an interim rule published on, January 15, 2020, the Department of Commerce, Bureau of Industry and Security (BIS), introduced expansive changes to General Prohibition 7 of the Export Administration Regulations (EAR) by including new controls on military-intelligence end uses and users, making the already tricky process of conducting business with foreign entities that much more complicated.
After minor corrections, a rule that many missed or ignored goes into effect on March 16, 2021. The rule will impact US companies and persons, as it affects the activities of US persons – even if the US person is not dealing with an item that is not subject to US export control laws! ....

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The Coup in Myanmar — U.S. Announces Initial Response with Targeted Sanctions and Export Controls | Pillsbury - Global Trade & Sanctions Law

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In response to the recent military coup in Myanmar (also known as Burma) against the democratically-elected government, on February 11, 2021 the Biden Administration issued an Executive Order on Blocking Property with Respect to the Situation in Burma (E.O.), which launched a new targeted sanctions regime. That same day, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated former and current officials of Burma’s military or security forces and affiliated entities in the jade and gems sector as Specially Designated Nationals (SDNs). In addition, the Commerce Department’s Bureau of Industry and Security (BIS) announced a series of steps to tighten export controls on certain ministries, armed forces, and security services, and to limit availability of license exceptions. It has been indicated that these are initial steps, and that further sanctions and export control may follow. ....

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