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Alexandre (Alex) Lamy (US)

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The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has restructured the location of penalty and enforcement procedure provisions within its regulations. On September 25, 2026, OFAC published a final rule creating 31 CFR Part 505, the Sanctions Penalties Regulations. Then, on September 30, 2026, OFAC issued a second related rule removing superseded penalties provisions and reorganizing remaining parts. These regulatory updates memorialize OFAC’s existing practices with enforcement matters but do not…

Since August 21, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has made a series of changes to the Venezuela-related general licenses (“GLs”) issued under the Venezuela Sanctions Regulations, 31 CFR part 591 (“VSR”). OFAC removed the US governing-law condition from the GLs that included it and updated the associated Frequently Asked Questions (“FAQs”). It issued two new GLs, (General License No. 61 (“GL 61”), since replaced by GL 61A,…

On August 13, 2026, the Trump Administration introduced a combination of trade measures intended to expand export opportunities for US unmanned aerial vehicle (UAV or drone) manufacturers while increasing incentives to source and produce drone technologies in the United States. The actions reflect a concerted approach to strengthen the US drone sector and address concerns about supply chain resilience and national security. Streamlined Export Controls The US Department of Commerce’s Bureau of Industry and Security…

On July 31, 2026, authorities from the United States, Japan, the Republic of Korea, Australia, Canada, France, Germany, Italy, the Netherlands, New Zealand, and the United Kingdom issued a joint alert warning countries, companies, and other entities about the threat posed by information technology (“IT”) workers of the Democratic People’s Republic of Korea (“DPRK” or “North Korea”). According to the alert, North Korea relies on a network of skilled IT workers, deployed both within and…