On January 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 24 (“GL”), which authorizes certain transactions formerly prohibited by several US sanctions programs. OFAC also issued eight new Syria Frequently Asked Questions (“FAQs”) and amended one existing FAQ, as part of its effort to ease certain trading restrictions after rebel forces toppled Syrian President Bashar al-Assad’s regime on December 8, 2024. General License No. 24 This…
On November 26, 2024, the US Commerce Departmentās Bureau of Industry and Security (āBISā) issued a final rule (āFinal Ruleā) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (āCCLā) that are subject to the Export Administration Regulations (āEARā). This expansion of controls is intended to address BISā concern that certain CCL items that are not currently controlled for Pakistan have…
On September 3, 2024, the US Department of Stateās Directorate of Defense Trade Controls (āDDTCā) issued revised Guidance for U.S. Persons Abroad (āUSPABsā) Authorization Requests (āUSPAB Guidanceā) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (āITARā), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABsā 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…