On December 7, 2023, the United States Commerce Department’s Bureau of Industry and Security (“BIS”) issued three new rules as a broad effort to ease export control requirements under the Export Administration Regulations (“EAR”) for key allied and partner countries. These rules were enacted in order to reduce the licensing requirement to export, reexport, and transfer US goods, software, and technology to and between allies and partners of the United States. The new rules are…
In the past week, both the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department and the Financial Crimes Enforcement Network (“FinCEN”) took steps related to Hamas, which they indicated were linked to the recent Hamas attacks on Israel. New OFAC Sanctions On October 18, 2023, OFAC added a number of parties determined to be connected to Hamas to its Specially Designated Nationals and Blocked Persons List (“SDN”). As described in the…
Introduction During September 2023, the US, UK, and EU, and Japan, updated their Common High Priority Items Lists (“the List(s)”), with seven new Harmonized System (“HS”) codes. These coordinated Lists are composed of items identified as critical to Russia’s war effort, weapons systems and military development. The Lists highlight to businesses that there is a particularly high risk these sanctioned items may be the target of sanctions circumvention and possible diversion to Russia. Companies can…
In two separate rounds of sanctions designations in the past week, the United States added more parties to the Specially Designated Nationals List (“SDN List”) maintained by the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department. These designations are noteworthy given their scope and, in the case of the Iran-related designations, the fact that they included parties in China, Russia, and Türkiye. Not only does this increase the risk of encountering sanctioned…