Commerce Identifies Five Countries And One Individual As "Foreign Adversaries"

On January 14, 2020 the Trump administration issued an interim rule identifying several countries and one individual as "foreign adversaries" under E.O. 13873, "Securing the Information and Communications Technology and Services (ICTS) Supply Chain." The new interim rule identifies nation-states China, Russia, Iran, North Korea, and Cuba, and Nicolás Maduro in his individual capacity, as foreign adversaries. This designation subjects certain transactions involving information and communications technology to heightened scrutiny, and those transactions may be prohibited.

You can read about E.O. 13873 in more detail here but in short, E.O. 13873 prohibits any acquisition, importation, transfer, installation, dealing in, or use of any information and communications technology or service (transaction) by any person, or with respect to any property, subject to the jurisdiction of the United States, if three prongs are satisfied, one of which is the designation of a