Rob O'Brien
- Speechwriter, European Medicines Agency
- Documentary Filmmaker, Freelance
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Br-Australian speechwriter @EMA_News. Documentary filmmaker 'The Adopted' 👇. Former Journalist @Independent @NikkeiAsia. #MECFS foot soldier. #grateful
Articles by Rob O'Brien
OFAC Designates the International Criminal Court and Issues Four Related General Licenses
On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC“) added the entire International Criminal Court (“ICC“) to the Specially Designated Nationals and Blocked Persons List (“SDN List“) pursuant to Executive Order 14203 (“EO 14203“) and issued four general licenses authorizing specified transactions involving the court. Designation of the ICC Under EO 14203 OFAC has designated the ICC under section 1(a)(ii)(A) of EO 14203.
US Rescinds Syria’s State Sponsor of Terrorism Designation and Delists Hay’at Tahrir al-Sham
On August 24, 2026, the US Department of State rescinded Syria’s designation as a State Sponsor of Terrorism (“SST”) and revoked the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (“HTS”), as a Specially Designated Global Terrorist (“SDGT”).
OFAC Issues General License Authorizing Agricultural and Medical Transactions and Activities Related to the Democratic Republic of the Congo and the Republic of Rwanda
On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region.
OFAC Venezuela Developments: New Conviasa Aircraft General License, Reissued Venezuela Telecom/Mail and PdVSA Bond Authorizations, and Updated FAQ 595
On June 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Venezuela-related general licenses and amended FAQ 595. The most notable development is new General License 59 (“GL 59”), which authorizes certain aircraft safety-related activities for Venezuelan Specially Designated National airline, Conviasa.
OFAC Venezuela Developments: New Conviasa Aircraft General License, Reissued Venezuela Telecom/Mail and PdVSA Bond Authorizations, and Updated FAQ 595
On June 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Venezuela-related general licenses and amended FAQ 595. The most notable development is new General License 59 (“GL 59”), which authorizes certain aircraft safety-related activities for Venezuelan Specially Designated National airline, Conviasa.
US Treasury Department Proposes Rule to Implement GENIUS Act’s Anti-Money Laundering and Sanctions Compliance Program Requirements for Stablecoin Issuers
On April 8, 2026, the US Department of the Treasury’s (“Treasury“) Financial Crimes Enforcement Network (“FinCEN“) and the Office of Foreign Assets Control (“OFAC“) issued a joint proposed rule (“Proposed Rule“) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act“).
US Treasury Department Proposes Rule to Implement GENIUS Act’s Anti-Money Laundering and Sanctions Compliance Program Requirements for Stablecoin Issuers
On April 8, 2026, the US Department of the Treasury’s (“Treasury“) Financial Crimes Enforcement Network (“FinCEN“) and the Office of Foreign Assets Control (“OFAC“) issued a joint proposed rule (“Proposed Rule“) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act“).
OFAC Issues New FAQ on Licensing the Resale of Venezuelan-Origin Oil to Cuba
On March 5, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an updated FAQ 1238, providing guidance on whether OFAC would approve license applications authorizing the resale of Venezuelan‑origin oil for use in Cuba when consistent with the terms and conditions of Venezuela General License (“GL”) 46A (authorizing US entities to export, sell, deliver, etc. Venezuelan-origin oil).
BIS Revises License Review Policy for Advanced Computing Commodities (AI Semiconductors) to China and Macau When Exported from the United States
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions.
OFAC Amends General Licenses for Certain Categories of Transactions Involving Lukoil Entities Outside of Russia and for Lukoil Retail Transactions
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here.
BIS Issues One-Year Suspension of New "Affiliates Rule"
On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) formally suspended the implementation of the “Affiliates Rule” for one year, as published in the Federal Register (linked here) on November 12, 2025. This suspension follows high-level trade negotiations between the United States and China, culminating in reciprocal concessions announced in late October and early November as discussed on our blog here and here.
BIS Introduces New “Affiliates Rule” Significantly Expanding Entity List, MEU List, and SDN End User Licensing Requirements Under the Export Administration Regulations
On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export Administration Regulations (“EAR”).
BIS Introduces New "Affiliates Rule" Significantly Expanding Entity List, MEU List, and SDN End User Licensing Requirements Under the Export Administration Regulations
On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export Administration Regulations (“EAR”).
‘The Adopted’: It’s up to us to keep the World War II generation alive
To connect schoolchildren to my documentary film I told them a love story about two British army officers with a twist in the tale. Press enter or click to view image in full size In December last year I stepped in front of a large group of schoolchildren from the British School in Amsterdam to screen a trailer for my documentary feature film, The Adopted, about Margraten’s World War II grave adoption program.
‘The Adopted’: From Lansing to Margraten, the past is always present
Our documentary feature follows the family of an American World War Two soldier as they visit the Dutch adopters of his grave. There’s a history lesson in here for us all. Three weeks ago, I was standing in the pouring rain in a German village called Kirchberg.
‘The Adopted’: From Lansing to Margraten, the past is always present
Our documentary feature follows the family of an American World War Two soldier as they visit the Dutch adopters of his grave. There’s a history lesson in here for us all. Press enter or click to view image in full size Three weeks ago, I was standing in the pouring rain in a German village called Kirchberg.
OFAC Updates Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion, Designates additional entities and vessels linked to the Iranian oil sector
On April 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and updated its Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (“the Advisory”), originally issued in September 2019. The updated Advisory is part of OFAC’s implementation of the February 4, 2025 National Security Presidential Memorandum (NSPM-2), which directs the Treasury Department to enact “maximum pressure” on Iran.
US Department of State Reinstates and Designates One Additional Party to Cuba Restricted List
On February 6, 2025, the US State Department reversed the Biden Administration’s revocation of President Trump’s National Security Presidential Memorandum 5 of June 16, 2017 and recreated the Cuba Restricted List (“CRL” or “List“), which identifies entities and subentities that are controlled by, or acting on behalf of, the Cuban military, intelligence, or security services or personnel. The US State Department also added a Cuban remittance provider to the CRL, effective March 10, 2025.
‘The Adopted’: I visited a WW2 soldier’s home in Michigan to see what he sacrificed
At his home in Lansing, his family shared the remarkable bond they have forged with the Dutch who adopted his grave. Rob O’Brien · Follow 10 min read · Feb 7, 2025 -- At the end of Ferguson Street in Lansing, Michigan, there is no way through for cars, but a small pathway leads down to an open field, where a football scoreboard stands alone in front of a row of houses. It’s a good place to grow up, and a beautiful place to come home to if you live elsewhere.
‘The Adopted’: I visited a WW2 soldier’s home in Michigan to see what he sacrificed
At his home in Lansing, his family shared the remarkable bond they have forged with the Dutch who adopted his grave. Press enter or click to view image in full size At the end of Ferguson Street in Lansing, Michigan, there is no way through for cars, but a small pathway leads down to an open field, where a football scoreboard stands alone in front of a row of houses. It’s a good place to grow up, and a beautiful place to come home to if you live elsewhere.
US Department of Commerce Significantly Expands Controls Targeting Indigenous Production of Advanced Semiconductors in China
On December 2, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS“) issued long anticipated and extensive new controls to impair China’s indigenous production of advanced semiconductors and other items that can be used in advanced weapon systems, AI, and advanced computing in support of China’s military-civil fusion program.
Global Sanctions and Export Controls Blog
On April 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and updated its Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (“the Advisory”), originally issued in September 2019. The updated Advisory is part of OFAC’s implementation of the February 4, 2025 National Security Presidential Memorandum (NSPM-2), which directs the Treasury Department to enact “maximum pressure” on Iran.
Takeaways from Baker McKenzie's Fireside Chat with Kyle Sullivan, VP at US-China Business Council
On November 12, 2024, as part of our 2024 Global Year-End Review of Import/Export & Trade Compliance Developments Conference, Baker McKenzie hosted an in-person fireside chat with Kyle Sullivan, Vice President of Business Advisory Services at the US-China Business Council (“USCBC“). In the discussion with Baker McKenzie’s Senior Counsel, John McKenzie, Mr. Sullivan discussed the changing commercial and business environment for US and multinational companies doing business in China.
Global Sanctions and Export Controls Blog
On April 11, 2025, the US Department of Justice National Security Division (āDOJā) took steps to implement its December 2024 Final Rule on Protecting Americansā Sensitive Data from Foreign Adversaries (āFinal Ruleā). Specifically, the DOJ issued answers to more than 100 Frequently Asked Questions (āFAQsā), published a Compliance Guide, and issued a Limited Enforcement Policy for the first 90 days of the Final Rule.
Final US Outbound Investment Security Rules Issued by US Treasury Department
On October 28, 2024, the US Treasury Department (“Treasury“) issued a long-anticipated final rule (“Final Rule“)—effective January 2, 2025—implementing a targeted outbound investment compliance regime called for by Executive Order (“EO“) 14105 issued by President Biden on August 9, 2023.
after | Shortverse
after A brother and sister visit their mother's countryside home after her sudden death and encounter a formidable force. Comments 0 Honors 0 Press Gallery 6 Credits 4 Details Add honors No honors Add press No press links Filmmaker Statement When Mum died suddenly on November 10, 2019, the world jolted on its axis. This happens when a giant pillar collapses — your mum, dad, brother, sister, friend, partner—everything shudders and, amid the rubble and dust, grief and chaos take the reins.
‘Adopters’: how the Dutch rallied to honour their liberators after WWII
It was summer, 2021. We were slowly emerging from the pandemic when I visited my in-laws in Sweikhuizen, a tiny village in Limburg, the southernmost province of the Netherlands. It’s a peaceful bolt hole from the city of Amsterdam, where I live with my family. One morning, my mother-in-law, Gerda, walked into the garden and picked some fresh flowers. “We gaan naar het kerkhof, Rob,” she announced.
US Government Imposes Additional Sanctions on Belarus and Russia Coinciding with Ukraine's Independence Day
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels.
OFAC Issues Guidance on the Extension of Statute of Limitations for Civil Violations Affecting Many OFAC Sanctions Programs
On July 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance relating to OFAC’s implementation of the 21st Century Peace Through Strength Act (“Act”), included in H.R. 815 and signed into law on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) from five to 10 years.
US Treasury Department Issues Proposed Rules Restricting US Outbound Investment in Advanced Technologies Involving China
On June 21, 2024, the US Treasury Department (“Treasury“) issued a much-awaited Notice of Proposed Rulemaking (“NPRM“)—pursuant to Executive Order (“EO“) 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern”—regarding the upcoming outbound investment review regime, which prohibits or, alternatively, requires notification of certain investments into entities linked to China and engaged in subsets of three...
OFAC Amends the Cuban Assets Control Regulations to Increase Support for the Cuban People and the Cuban Private Sector, Including Certain Internet-based Communications Services and Financial Transactions
On May 28, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations (“CACR”) and issued new and updated frequently asked questions (“FAQs”) to further implement a policy originally announced by the Biden Administration on May 16, 2022 to increase support for the Cuban people and private sector entrepreneurs.
The US and UK Announce Further Sanctions and Export Restrictions Targeting Iran
On April 18, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) and the UK’s Foreign, Commonwealth & Development Office (“FCDO”) announced a coordinated sanctions package targeting Iran.
Blog Series: Navigating the Impending Global Sanctions Enforcement Storm - How To Approach First Steps
In an era where regulatory compliance is under intense scrutiny, the importance of a well-orchestrated response to trade and sanctions investigations cannot be overstated. An investigation may involve transactions occurring in multiple jurisdictions, laws of separate jurisdictions, and inquiries from (or disclosures to) multiple governmental authorities.
US Department of Justice Revises National Security Division Self-Disclosure Policy
On March 7, 2024, the US Department of Justice (“DOJ”) National Security Division (“NSD”) published a revised (“Enforcement Policy”). The Enforcement Policy was first issued by the NSD on December 13, 2019 and subsequently updated March 1, 2023. Our blog post discussing the original policy is here.
Whatever Happens, Grief Will Have Her Way
Shaken by her sudden death I took a camera into mum’s house to tell her story, my way. But grief had other plans. When Mum died suddenly on November 10, 2019, the world jolted on its axis. This happens when a giant pillar collapses — your mum, dad, brother, sister, friend, partner—everything shudders and, amid the rubble and dust, grief and chaos take the reins. I checked my phone and her avatar was still there; I had four missed calls from her. How?
Whatever happens, grief will have her way
Shaken by her sudden death I took a camera into mum’s house to tell her story, my way. But grief had other plans. When Mum died suddenly on November 10, 2019, the world jolted on its axis. This happens when a giant pillar collapses — your mum, dad, brother, sister, friend, partner—everything shudders and, amid the rubble and dust, grief and chaos take the reins. I checked my phone and her avatar was still there; I had four missed calls from her. How?
Advice on Digital Transformation, from ITV Studios and Zoho
Michael Krigsman: Today we're talking with Rob O'Brien who is the head of International Technology for ITV Studios. We're discussing the digital transformation of television production, and we're here in McAllen, Texas with Zoho. Rob O'Brien: ITV POC is a commercial broadcaster, the biggest in the UK, and a production business. I'm the head of international technology.
Takeaways from Baker McKenzie's Webinar with Assistant Secretary of Export Enforcement Matthew Axelrod, US Commerce Department's Bureau of Industry and Security
On January 30, 2024, Baker McKenzie, in partnership with the International Compliance Professionals Association, hosted a virtual fireside chat with Matthew Axelrod, the Assistant Secretary for Export Enforcement for Bureau of Industry and Security (“BIS”) in the US Commerce Department. The webinar attracted 3,200 registrations from across industry, with participants raising a wide variety of questions.
House Committee Chairman Issues Report on Problems and Recommendations for BIS to Strengthen US Export Controls
On December 7, 2023, Chairman Michael McCaul of the Foreign Affairs Committee in the House of Representatives released a 90-Day Review Report (the “Report”) of the US Bureau of Industry and Security (“BIS”), the agency tasked with administering the Export Administration Regulations (15 C.F.R Parts 730–774, the “EAR”) under the US Commerce Department.
US Government Provides Limited Relaxation of Venezuela Sanctions Through New and Amended OFAC General Licenses
On October 18, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) implemented limited sanctions relief under the Venezuela Sanctions Regulations (the “VSR”) to the Government of Venezuela (the “GOV”) and certain sectors of the Venezuelan economy in response to the signing of an electoral roadmap agreement between GOV representatives and Venezuelan political opposition parties.
United States: Government issues Executive Order restricting outbound investment in advanced technologies involving “countries of concern”
On August 9, 2023, President Biden issued Executive Order 14105, targeting certain US investments into Chinese companies or Chinese-owned companies engaged in three advanced technology areas (Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, the “EO”).
US Government Issues Executive Order Restricting US Outbound Investment in Advanced Technologies Involving “Countries of Concern” (China)
On August 9, 2023, President Biden issued Executive Order 14105, targeting certain US investments into Chinese companies or Chinese-owned companies engaged in three advanced technology areas (Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern, the “EO”).
United States: Commerce Department revises the Securing the Information and Communications Technology and Services Supply Chain Regulations
On June 16, 2023, the US Commerce Department published a final rule (“Final Rule”), implementing President Biden’s 2021 Executive Order 14034 on “Protecting Americans’ Sensitive Data from Foreign Adversaries,” to amend the Commerce Department’s “Securing the Information and Communications Technology Supply Chain” regulations, 15 C.F.R. Part 7 (“ICTS Regulations”). The amendments mainly relate to connected software applications.
Commerce Department Revises the Securing the Information and Communications Technology and Services Supply Chain Regulations
On June 16, 2023, the US Commerce Department published a final rule (“Final Rule”), implementing President Biden’s 2021 Executive Order 14034 on “Protecting Americans’ Sensitive Data from Foreign Adversaries,” to amend the Commerce Department’s “Securing the Information and Communications Technology Supply Chain” regulations, 15 C.F.R. Part 7 (“ICTS Regulations”). The amendments mainly relate to connected software applications.
Marjolein vs. The Mangrove
I was upstairs when the phone call came in. There was a pause followed by a muffled cry from downstairs in our Amsterdam apartment where my wife lies during the daytime. We knew the call was coming, but the sucker punch still hurt like hell. After the scream, came the sobbing. And after the sobbing, came the rage. I heard this and ran downstairs with my audio recorder and within seconds I was kneeling by her side as she lost her disability benefits.
When air travel rebounds, will sustainability be a concern for business travellers?
Sustainability is now a key priority among business travelers, say experts. Image: Raul Pacheco-Vega/Flickr Almost every country in the world has imposed travel restrictions amid the Covid-19 pandemic, forcing businesses to cancel travel, events and embrace digital communications. But as vaccine programmes roll out across the world, many are keen for a return to business as usual.
As European meat-lovers resist change, Asia shows biggest appetite for plant-based future
Far from ditching meat, consumption continues to grow across Europe. Meat sales increased 15 to 20 per cent in the first three quarters of 2020. Image: Tetyana Bunyak/Flickr Despite a tumultuous year globally for the meat industry, European food habits avoided large scale disruption with meat sales surging amid lockdowns in 2020. Far from ditching meat, consumption continues to grow across Europe.
Making film stars out of Singapore’s domestic workers
The shoestring budget film Remittance depicts the hardship of life in Singapore through its ensemble cast of real life domestic workers. But now they are waiting for its message to reach the people who matter most — their family and friends at home.
The naughty angel
I don’t know what to say. How do I fit the life of someone I love so much into a finite amount of time? Where do I start? It can’t be done. I can’t do justice to her love, humour, intelligence and unique brand of mischief. I’m staring at a blank piece of paper. What has comforted me is an image of mum that has appeared to me every night since she left. A snapshot from a trip we took with Mike and Pauline Dawson to Hoi An in Vietnam.
Health workers have always put their lives on the line, we should be clapping them every day.
A few months ago I hobbled into my local hospital, the University Medical Center in Amsterdam, with a broken leg from playing football. I was taken to a ward equipped with monitoring equipment as my busted tibia throbbed with each surge of adrenaline. A mate sat with me and the gallows humour began. There was only one other patient there with his girlfriend, otherwise that part of the hospital was empty and overstaffed.
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