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…
On April 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued General License 13R (“GL 13R”) and General License 15L (“GL 15L”), narrowing those authorized activities with GAZ Group and entities owned 50% or more by GAZ Group (“GAZ”), as further described below. OFAC also issued a set of updated FAQs to clarify the scope of authorized activities under these GLs. Our most recent blog post on these GLs is available…