On May 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R Part 560 (“ITSR”), to incorporate OFAC General License (“GL”) D-2 and the preexisting list of items deemed incident to communications that are authorized for export or reexport to Iran under GL D-2, and to concurrently update such list. OFAC also published one new and 26 revised…
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 14, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced more restrictive export controls on Nicaragua stated to be in response to the Nicaraguan Government’s human rights abuses, attacks on civil society, and increased cooperation with Russia. The DDTC and BIS press releases are available here and here. DDTC: New ITAR Export Controls The State Department announced…
On January 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…