On March 2, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”), the US Department of Justice (“DOJ”), and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls (“Compliance Note”) warning the public of efforts to evade Russia-related sanctions and export controls via use of third-party intermediaries and transshipment points. To aid the…
On January 26, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) redesignated PMC Wagner (“Wagner Group”) a Significant Transnational Criminal Organization (“STCO”) pursuant to Executive Order 13581 (“EO 13581”) as amended by Executive Order 13863 (“EO 13863”) for the Wagner Group’s activities in Ukraine, the Central African Republican (“CAR”), and Mali. Concurrently, OFAC has sanctioned the Wagner Group under Executive Order 13667 (“EO 13667”) for its activities in the CAR.…
On January 5, 2023, President Biden signed the Protecting American Intellectual Property Act into law. This law seeks to deter the theft of US intellectual property by non-US actors by threatening to impose economic sanctions on those engaged in trade secrets theft. This law adds to existing measures available under US law, such as criminal prosecution, civil lawsuits, and/or designation to a US restricted parties list such as the Entity List (maintained by the US…
On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…