Jana del-Cerro

Firm/Organization: Crowell & Moring LLP

Blogs: International Trade Law

Latest Articles

International Trade Law

State Department Publishes Long Awaited Cloud Computing Rule

By Alan W. H. Gourley & Jana del-Cerro

January 15, 2020

On December 26, 2019, the State Department issued an interim final rule that nearly mirrors the changes adopted by the Commerce Department in 2016. The new ITAR rule will allow for cloud based storage and handling in the U.S. and abroad of appropriately encrypted ITAR controlled software and technical data. It will take effect on March 25, 2020, but allows 30 days for public comment (until January 27, 2020) and perhaps further revision by…

International Trade Law

Congress Passes New Russia and Venezuela Sanctions and Advances New Russia & Turkey Sanctions

By Dj Wolff, Jeff Snyder, Carlton Greene, Addie Cliffe, David Baron, Nicole Succar, Erik Woodhouse, Jana del-Cerro, Brian McGrath & Nimrah Najeeb

December 27, 2019

Dec.27.2019 As 2019 draws to an end, Congress has been busy on economic sanctions legislation. This includes passing new Russia-related sanctions and a Venezuela-related government contracts procurement restriction as part of the National Defense Authorization Act for Fiscal Year 2020 (NDAA 2020). The U.S. Senate Foreign Relations Committee has also approved two new pieces of legislation that would increase sanctions on Russia and Turkey, respectively. Full details on each of these developments are below the…

International Trade Law

Commerce to Publish Proposed Regulations to Implement EO on “Securing the Information and Communications Technology and Services Supply Chain”

By Jeff Snyder, Addie Cliffe, Jana del-Cerro & Paul Freeman

November 26, 2019

The Commerce Department will publish, in proposed form, long-awaited regulations to implement the sweeping language of the May 2019 Executive Order entitled “Securing the Information and Communications Technology and Services Supply Chain.” The proposed regulations, to be promulgated under the authority of the International Emergency Economic Powers Act (IEEPA) and the EO, would establish a case-by-case process, by which the Secretary of Commerce could initiate (at its discretion, or at the request of another…

International Trade Law

New Sanctions Imposed on Elements in the Turkish Government

By Carlton Greene, Dj Wolff, Alan W. H. Gourley, Nicole Succar & Jana del-Cerro

October 21, 2019

On October 14, 2019, the Trump Administration followed through on its recent threats by issuing a new Executive Order (EO) (as yet unnumbered) establishing sanctions that effectively target the Turkish Government in response to the latter’s military intervention into Northern Syria. Using this authority, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) simultaneously added both the Turkish Ministry of Energy and Natural Resources and the Turkish Ministry of National Defence, as…

International Trade Law

United States Ramps Up Sanctions Pressure on Russia and Venezuela

By Dj Wolff, Carlton Greene, Nicole Succar, Jana del-Cerro & Erik Woodhouse

August 13, 2019

Over the course of the last week, the United States has escalated its sanctions programs targeting Russia and Venezuela. It began by implementing the long-delayed second round of sanctions on Russia mandated by the Chemical and Biological Weapons Act of 1991 (CBW Act) on Saturday, August 3, 2019. While the CBW sanctions will have a limited impact on most companies, the same cannot be said of the issuance of Executive Order 13884 (“E.O. 13884”) on…

International Trade Law

Identifying and Defining “Emerging Technologies” Subject to Control for Export and Foreign Investment

By Alan W. H. Gourley, Addie Cliffe & Jana del-Cerro

November 19, 2018

On November 19, 2018, the Bureau of Industry and Security (BIS) published an advance notice of proposed rulemaking (ANPRM) seeking comments on implementation of Section 1758 of the Export Control Reform Act of 2018. This section requires Commerce, in consultation with DoD and other CFIUS member agencies, to define “emerging technologies” sufficiently significant to U.S. national security interests to impose some level of export controls over the technology and potentially to trigger mandatory declarations of…

International Trade Law

United States Reinstates Full Iran Embargo

By Dj Wolff, Jana del-Cerro & Adeoye Johnson

November 6, 2018

On November 5, 2018, in accordance with President Trump’s May 8, 2018 decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an amendment to the Iranian Transactions and Sanctions Regulations (ITSR). The amendment followed on the expiration of the final 180-day wind-down period for transactions previously authorized by “General License H” and for the re-imposition of the remaining “secondary sanctions,” which…

International Trade Law

DDTC Requests Industry Testing for New Registration and Advisory Opinion Applications

By Jana del-Cerro, Chris Monahan & Edward Goetz

October 17, 2018

The Directorate of Defense Trade Controls (DDTC) announced this week that it will post test versions of its new Registration and Advisory Opinion (AO) applications on the cloud-based Defense Export Control and Compliance System (DECCS) for industry testing and feedback starting October 16th through mid-November 2018. If a company is interested in participating in this testing, DDTC asks to please contact the DDTC Test Support Team at the number or email below to sign up…

International Trade Law

U.S. National Security Review of Foreign Investment: Revisions to CFIUS Legislation Signed Into Law

By Addie Cliffe, Alan W. H. Gourley, Philip B. Rosen & Jana del-Cerro

August 21, 2018

On August 13, 2018, the President signed the National Defense Authorization Act for Fiscal Year 2019 which includes the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) updating national security reviews performed by the Committee on Foreign Investment in the United States (CFIUS). Some FIRRMA provisions are effective immediately, but the effective date of others requires formal rulemaking to be completed within the next 18 months. Included in the provisions effective immediately is a…

International Trade Law

Plugging the “Gaps” on Transfers of U.S. Sensitive Emerging Technology: Dual-Use Export Control Statutory Authority Becomes Law

By Alan W. H. Gourley, Addie Cliffe, Jana del-Cerro & Chris Monahan

August 16, 2018

The Export Control Reform Act of 2018, included within the National Defense Authorization Act (NDAA) for Fiscal Year 2019, became law on August 13, 2018, and provides “modern” and permanent statutory authority for the U.S. Export Administration regulations (EAR), which control the export, re-export, and transfer of U.S. origin “dual-use” items. As a result of the effort to strengthen control over foreign investment in the United States (contained in a companion statute within the NDAA),…

Jana del-Cerro

State Department Publishes Long Awaited Cloud Computing Rule

Congress Passes New Russia and Venezuela Sanctions and Advances New Russia & Turkey Sanctions

Commerce to Publish Proposed Regulations to Implement EO on “Securing the Information and Communications Technology and Services Supply Chain”

New Sanctions Imposed on Elements in the Turkish Government

United States Ramps Up Sanctions Pressure on Russia and Venezuela

Identifying and Defining “Emerging Technologies” Subject to Control for Export and Foreign Investment

United States Reinstates Full Iran Embargo

DDTC Requests Industry Testing for New Registration and Advisory Opinion Applications

U.S. National Security Review of Foreign Investment: Revisions to CFIUS Legislation Signed Into Law

Plugging the “Gaps” on Transfers of U.S. Sensitive Emerging Technology: Dual-Use Export Control Statutory Authority Becomes Law

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