On November 26, 2024, the US Commerce Departmentâs Bureau of Industry and Security (âBISâ) issued a final rule (âFinal Ruleâ) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (âCCLâ) that are subject to the Export Administration Regulations (âEARâ). This expansion of controls is intended to address BISâ concern that certain CCL items that are not currently controlled for Pakistan have…
On September 3, 2024, the US Department of Stateâs Directorate of Defense Trade Controls (âDDTCâ) issued revised Guidance for U.S. Persons Abroad (âUSPABsâ) Authorization Requests (âUSPAB Guidanceâ) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (âITARâ), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABsâ non-US employers. The principal changes to the USPAB Guidance are as follows:
On July 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued guidance relating to OFAC’s implementation of the 21st Century Peace Through Strength Act (“Act”), included in H.R. 815 and signed into law on April 24, 2024, which extended the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) from five to 10 years. Together, the…
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…