August - 2020

OFAC publishes new Sudan program and Darfur sanctions guidance and FAQs

On 11th August 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published the Sudan Program and Darfur Sanctions Guidance, a Frequently Asked Question (FAQ), and removed 11 Sudan-related FAQs. OFAC also amended Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) FAQ 5, FAQ 97, FAQ 98, FAQ 500, FAQ 36, FAQ 42, FAQ 91, FAQ 126 and FAQ 398.

U.S. further restricts Huawei

Effective 20th August 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has modified controls on Huawei and its listed non-U.S. affiliates. This ruling: adds 38 additional non-U.S. Huawei affiliates to the Entity List. removes a temporary general license for Huawei and affiliates and replaces it with a more limited permanent authorization that excludes certain additional exports, reexports, and transfers (in-country). amends General Prohibition Thr

China announces retaliatory sanctions against the U.S.

On 10th August 2020, China’s Foreign Ministry Spokesperson Zhao Lijian announced sanctions against 11 U.S. individuals. These sanctions were a retaliation for the 11 individuals sanctioned by the U.S. Department of the Treasury on 7th August 2020. The U.S. Treasury press release states that the U.S. sanctions were due to the undermining of “Hong Kong’s autonomy and restricting the freedom of expression or assembly of the citizens of Hong Kong.” China’s response is that the U.

U.S. executive orders target TikTok and WeChat

On 6th August 2020, U.S. President Trump issued Executive Order 13942 and 13943 against TikTok and WeChat, respectively. TikTok, a video-sharing mobile app owned by ByteDance Ltd., and WeChat, a messaging, social media and mobile payment app owned by Tencent Holdings Ltd., are cited as threats to the “national security, foreign policy, and economy of the United States” because of their prolific use in the U.S. and because they are developed and owned by Chinese companies. The

UK revises and revokes Hong Kong’s open general licences

Following a statement made by the United Kingdom’s Foreign Secretary on 20th July 2020, the UK’s Department for International Trade: Export Control Joint Unit has extended China’s arms embargo to include Hong Kong and has indefinitely suspended the UK-Hong Kong extradition treaty. The arms embargo dictates that UK will not export “potentially lethal weapons, their components or ammunition” to Hong Kong. Furthermore, any equipment that might be used for “internal repression” (

EU imposes first sanctions against cyber-attacks

On 30th July 2020, the European Union imposed sanctions against six individuals and three entities for responsibility and/or involvement in cyber-attacks against the EU. These cyber-attacks included those against the Organisation for the Prohibition of Chemical Weapons (OPCW), and attacks known as “NotPetya,” “Operation Cloud Hopper” and “WannaCry.” This is the first time the EU has used the Framework for a Joint EU Diplomatic Response to Malicious Cyber Activities (the "cybe

European Commission extends relief for VAT and customs duties on medical equipment imports

On 23rd July 2020, the European Commission extended the temporary relief of VAT and customs duties on imported medical equipment from third countries in order to assist member states in the fight against the coronavirus pandemic. EU member states can now waive import duties and VAT on masks, protective equipment, testing kits, ventilators and other medical equipment until 31st October 2020. For further information see the announcement by the Commission.

OFAC amends Ukraine-/Russia-related Frequently Asked Questions

On 22nd July 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published nine amended Ukraine-/Russia-related Frequently Asked Questions (FAQs) pertaining to Ukraine-/Russia-related General Licenses 13O and 15I (see previous post). For further information please see OFAC’s Recent Actions and FAQs 570, 571, 586, 588, 589, 590, 591, 592 and 625.