On November 21, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued Russia-related General License 13C, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13B”), which amends and replaces the former GL 13B. The authorization of GL 13C is extended through 12:01 a.m. Eastern time on March 7, 2023. This is the third time an extension has been granted. GL 13B was previously set to expire…
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 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of State, issued the Russia-related Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex (“the Alert”). OFAC also published one new Russia-related frequently asked question (“FAQ”). The Alert outlines impacts of the coordinated sanctions and export controls that have led to shortages of supplies…
On September 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “Sanctions Compliance Guidance for Instant Payment Systems” (the “Guidance”). The Guidance underscores the importance of a risk-based approach to managing sanctions risks related to payment technologies such as instant payment systems. The availability of funds in real time poses a challenge for financial institutions that seek to comply with US sanctions regulations. OFAC recommends that developers of instant…