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Alex Lamy

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On January 19, 2021, the US Commerce Department (“Commerce”) published an interim final rule (“Interim Rule”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services (“ICTS”) Supply Chain.” The Interim Rule was issued following the public comment period’s closure on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”). For more information on the Proposed Rules and the Interim Rule, please see our blog posts here and here. When it requested comments on…

On April 20, 2021, the Biden Administration took steps to address cybersecurity risks in the US energy sector industrial base by announcing a 100-day cybersecurity initiative for electricity subsector industrial control systems (“100-Day Plan”) and by issuing, on April 22, 2021, a Request for Information to inform future recommendations for US energy systems’ supply chain security (“RFI”). Public comments in response to the RFI are due by June 7, 2021. These actions support the Biden…

When companies and compliance departments think about US sanctions and export control risks, they often focus on sales to customers and exports/reexports from one country to another. In that context, the attention is typically on confirming that a customer and other parties involved in a sale and shipment are not restricted parties and that the transfer of a product is authorized under applicable export-control regulations. This is only half the story. Companies can have similar…