On February 9, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 23, “Authorizing Transactions Related to Earthquake Relief Efforts in Syria.” General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (“SySR”) through 12:01 p.m. eastern daylight time, August 8, 2023. General License 23 does not authorize importation of petroleum or petroleum products of…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 13,…
On October 28, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a first round of FAQs regarding the advanced computing and semiconductor manufacturing Interim Final Rule, published on October 13, 2022 (87 Fed. Reg. 62,186) (the “Rule”) and amending the Export Administration Regulations (“EAR”). The FAQs are available here and the Rule is available here. Our blog post related to the Rule is located here. The FAQs address certain questions around:…
On October 7, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued the much anticipated rules aimed at restricting China’s ability to obtain advanced computing chips, develop and maintain supercomputers, and manufacture advanced semiconductors (“Rule”) (87 FR 62186). In addition to formalizing the licensing requirements included in the recent BIS “is informed” letters issued to certain US companies on related matters, the Rule imposes a wide range of new and enhanced restrictions…