WebMar 26, 2024 · FAQ 883 indicates that for the duration of GL No. 4, non-US persons may wind down transactions involving MEC, MEHL, or any entity in which MEC or MEHL directly or indirectly owns a 50% or greater interest, without exposure to secondary sanctions under EO 14014, provided that such wind-down activity is consistent with GL No. 4. It also … WebJun 11, 2024 · The only opportunity to flag if an entity is 50% owned by a denied party is to have this information available when denied (or restricted) party screening occurs. Especially for companies with larger transaction …
BIS Issues FAQs Relating to the Military End Use/User Rules
WebDec 16, 2024 · The Entity List is a tool utilized by BIS to restrict the export, reexport, and in-country transfer of items subject to the EAR to persons (individuals, organizations, … WebA 50% narrative sanctions applies to an entity not sanctioned by name or appearing on a blocked / restricted entity list but is covered by a narrative statement on a sanctions program extending such sanctions to such non-listed entity. Firms face the challenge of understanding to what extent they should screen their customers and key ... simon rabbit snow
Russia and Belarus Targeted With Comprehensive Economic …
WebMar 7, 2024 · From a U.S. enforcement perspective, be aware of (i) the OFAC 50% rule, whereby any entity owned 50% or more in the aggregate by an SDN(s) is also considered to be an SDN by OFAC, regardless of ... WebDec 21, 2024 · The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule amending the Export Administration Regulations (“EAR”) … WebThe Entity List is found in Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR) (15 C.F.R. Part 744, Supp. No. 4). The most recent version of the … simon rabbit characters