Author

Bart M. McMillan

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On October 18, 2023, the US Departments of Commerce, State, Treasury, and Justice issued the Iran Ballistic Missile Procurement Advisory (the “Advisory”) to alert persons and businesses to Iran’s ballistic missile procurement activities. The Departments of State and Justice also issued separate statements related to the Advisory. The Advisory and related statements underscore the US Government’s concerns about Iran’s ballistic missile program and its efforts to stymie that program. In addition, the US Government and…

On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…

On June 27, 2023, the US Departments of State, the Treasury, Labor, Commerce, and Homeland Security, and the United States Agency for International Development issued a joint advisory — the Africa Gold Advisory (“Advisory”) — that (i) highlights the opportunities and specific risks raised by the gold trade across sub-Saharan Africa and (ii) encourages industry participants to adopt and apply strengthened due diligence practices to guard against such risks. The Advisory states that it was…

On May 19, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) implemented further economic sanctions and export controls targeting Russia and Belarus. The OFAC press release and BIS press release both underscore the US Government’s close coordination with international partners and allies to align new restrictions on Russia and Belarus. In addition, the Leaders of the G7 released…