On January 29, 2018, the US Treasury Department (“Treasury”) delivered five reports to Congress, as required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). Please see our prior blog post on CAATSA here. Among these reports was a list identifying Russian senior political figures, oligarchs, and parastatal entities pursuant to CAATSA Section 241. This report was released during the same week that other CAATSA sanctions targeting Russia have gone into effect.
On October 6, 2017, the US Government announced that it will revoke certain sanctions with respect to Sudan and the Government of Sudan, effective October 12, 2017. As a result of the revocation, US Persons will no longer be prohibited from engaging in Sudan-related transactions that were previously prohibited under the Sudanese Sanctions Regulations (“SSR”), including dealings with the Government of Sudan, and the SSR will be removed from the US Code of Federal Regulations.
On June 20, 2017, the US Office of Foreign Assets Control (“OFAC”) announced that it had added 38 individuals and entities to the Specially Designated Nationals and Blocked Persons List (“SDN List”) and 20 entities to the Sectoral Sanctions Identification List (“SSI List”) under US sanctions targeting Russia and Crimea. On June 21, 2017, the US Bureau of Industry and Security (“BIS”) also announced that it would add some of these SDN entities to the Entity List.
On February 8, 2017, the US Bureau of Industry and Security (“BIS”) announced that it has updated the content of its Export Compliance Guidelines (“Guidelines”) and Audit Module (“Module”) and combined both documents into one “easy-to-use” booklet. We understand that BIS’s primary purpose in updating the Guidelines and Module was to shorten and simplify them because, in BIS’s view, the prior versions of the documents were too long and contained too much unnecessary technical language.