The US Bureau of Industry and Security (“BIS”) has issued a Final Rule that coordinates the Export Administration Regulations (“EAR”) with the US Department of the Treasury’s Office of Foreign Assets Control’s (“OFAC”) Specially Designated Nationals and Blocked Persons (“SDN”) list. Under 11 of OFAC’s SDN programs – terrorism, weapons of mass destruction, narcotics, and Russia’s invasion of Ukraine, to name a few – the designations will trigger end-user restrictions under the EAR, 15 C.F.R. 744....
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