On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…
On June 30, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced four key policy changes to strengthen the administrative enforcement program and tackle external threats. These policy changes prioritize the “most serious violations” and cases that pose the greatest danger to US security. The four policy changes made to the BIS’s Administrative Enforcement Program include: Imposition of Significantly Higher Penalties The most serious administrative violations will trigger more stringent penalties…
On June 2, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added additional Russian and Belarussian entities to the BIS Entity List, enacted new licensing requirements for food, medicine for military end-users on the Entity List, and stated that they would be making charging letters public in a pair of Final Rules (here and here). We have outlined these developments in additional detail below. Additions of Russian and Belarusian Entities…
On May 16, 2022, the Biden administration announced the relaxing of certain limited Cuban sanctions and other regulatory changes to expand communication, travel, and commerce between the United States and Cuba. The related fact sheet can be found here. The US State Department outlined four changes to Cuba policy in the announcement: Facilitate family reunification: The Cuban Family Reunification Parole Program will be reinstated and capacity for consular services and visa processing will continue to…