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Bart M. McMillan

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Bart McMillan leads the Chicago Office’s International Trade Compliance Subpractice within the North American International Commercial Practice. He advises US and non-US companies on international trade compliance matters arising under US export controls, trade sanctions, and antiboycott rules, as well as under US customs laws with respect to classification, valuation, country of origin, free trade agreements, and the protection of intellectual property at the US border. His practice also covers anti-bribery and specialized commercial compliance issues in sales and sales promotion under the US Foreign Corrupt Practices Act (FCPA), non-US anti-bribery law, and non-US commercial laws. Mr. McMillan has been practicing with Baker McKenzie for the entirety of his legal career, and during 2004 he was located in the Washington, DC office. He is a frequent speaker on international trade compliance matters at seminars, conferences, and company training events. While pursuing his J.D. at NYU School of Law, Mr. McMillan was Staff Editor (1997-98) and Associate Editor (1998-99), New York University Law Review; and he participated in a semester exchange to the Central European University (Budapest) (Legal Studies Dep’t).

On 23 August 2023, the US Treasury Department’s Office of Foreign Assets Control issued the first Determination Pursuant to Section 1(a)(i) of Executive Order 14014, which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions: FAQ 1132 and FAQ 1133.

On 27 June 2023, the US Departments of State, the Treasury, Labor, Commerce, and Homeland Security, and the United States Agency for International Development issued a joint advisory — the Africa Gold Advisory — that (i) highlights the opportunities and specific risks raised by the gold trade across sub-Saharan Africa and (ii) encourages industry participants to adopt and apply strengthened due diligence practices to guard against such risks.

On 30 March 2023, the White House and US Department of Commerce’s Bureau of Industry and Security announced human rights and export control measures that underscore the US Government’s focus on human rights as a matter of foreign policy. The White also issued a Fact Sheet that includes these announcements and other sanctions and export control provisions.

Baker McKenzie’s Sanctions Blog published the alert titled US Government Designates Russian Proxy Wagner Group as a Significant Transnational Criminal Organization; Sanctions Wagner Group Affiliates, Oligarch Affiliates, and Military Industrial Complex Firms on 31 January 2023. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

Baker McKenzie’s Sanctions Blog published the alert titled OFAC and BIS Designate Additional Russian Parties, Signal Readiness to Act Against Third-Country Entities Assisting Russia and Belarus on 5 October 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

Baker McKenzie’s Sanctions Blog published the alert titled OFAC amends existing and issues new General Licenses under Russia sanctions to authorize pension payments to non-US persons outside of Russia and closing individual accounts at blocked banks on 29 August 2022. Read the article via the link here. Please also visit ourSanctions Blog for the most recent updates.

Baker McKenzie’s Sanctions Blog published the alert titled BIS Adds to Entity List and Imposes License Requirement for Food/Medicine to Russian/Belarussian Military End Users; Commerce Charging Letters to Become Public on 1 July 2022. Read the article via the link here. Please also visit our Sanctions Blog for the most recent updates.

On 16 May 2022, the Biden administration announced the relaxing of certain limited Cuban sanctions and other regulatory changes to expand communication, travel, and commerce between the United States and Cuba. Following this, on 9 June 2022, the Department of the Treasury’s Office of Foreign Assets Control amended the Cuban Assets Control Regulations to implement some of the elements of the President’s foreign policy to increase support for the Cuban people.