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Orfeh Vahabzadeh

Orfeh is an associate in the Firm's international trade practice in Washington, DC, advising companies on export controls, sanctions, and supply chain compliance. She advises US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions, and enforcement matters.

On 28 October 2022, the US Commerce Department’s Bureau of Industry and Security issued a first round of FAQs regarding the advanced computing and semiconductor manufacturing Interim Final Rule, published on 13 October 2022 (87 Fed. Reg. 62,186) and amending the Export Administration Regulations. The FAQs clarify that that the new restrictions on exports and reexports to China also apply to Hong Kong.

On 20 October 2022, the US Treasury Department released the first Committee on Foreign Investment in the United States Enforcement and Penalty Guidelines. The Guidelines provide visibility into factors CFIUS considers when assessing violations of CFIUS laws and regulations, and determining potential penalties. The Guidelines are applied by the Monitoring and Enforcement office, which is part of the US Treasury Department’s Office of Investment Security.

Following initial announcements last year, on 20 July 2022 the US Department of State’s Directorate of Defense Trade Controls (DDTC) published two Open General Licenses (OGLs) permitting certain reexports and retransfers to certain parties under the International Trade in Arms Regulations. The OGLs, which are part of a DDTC pilot program, will be valid for one year, effective from 1 August 2022 through 31 July 2023.

US federal government agencies charged with implementing President Biden’s February 24, 2021 Executive Order 14017 continue to assess supply chain risks and vulnerabilities by issuing public requests for comment. Among other things, the Supply Chain EO directs the heads of several federal agencies to conduct a one-year review to examine supply chains for potential vulnerabilities in a number of sectors.