On March 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule, effective April 4, 2024 (“April 2024 IFR”) to correct inadvertent errors made in prior semiconductor-related rules in the Export Administration Regulations (“EAR”) and further clarify such rules. The April 2024 IFR clarifies the (1) “Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections” (88 FR 73458, October…
On March 6, 2024, the US Department of Justice (“DOJ”), Department of Commerce’s Bureau of Industry and Security (“BIS”), and Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) jointly issued a compliance note titled “Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with US sanctions and export control laws” (“Tri-Seal Compliance Note”). This note highlights longstanding US sanctions and export controls that apply to non-US companies and individuals as well as the…
On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) revoked General License 43 (“GL 43”), which authorized certain transactions involving CVG Compania General de Mineria de Venezuela CA (“Minerven”). GL 43 was replaced with GL 43A to allow US Persons, through 12:01 a.m. eastern standard time, February 13, 2024, to wind down transactions involving Minerven (and entities it owns 50% or more) that were previously authorized by GL…
On November 2, 2023, the United States government issued new Russia-related sanctions targeting more than 200 individuals and entities. OFAC also issued three new Russia-related General Licenses and reissued another one, and the US Department of Commerce Bureau of Industry and Security (“BIS”) added 13 entities to the Entity List. SDN Designations The US Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the US Department of State added a range of targeted…