On February 21, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued OFAC Compliance Communique: Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (“Guidance”). The Guidance responds to specific questions OFAC received related to earthquake relief efforts in Syria and explains how to provide humanitarian assistance to the Syrian people in compliance with US sanctions. The Guidance follows Syria General License 23, issued by OFAC on February…
On December 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued “Preliminary Guidance on Implementation of the Price Cap Policy for Petroleum Products of Russian origin” to explain how OFAC will implement a ban on the provision of services related to the maritime transportation of Russian-origin petroleum products (“Petroleum Products Guidance”). The petroleum products ban builds on a similar ban related to maritime transportation of Russian-origin crude oil that…
On October 7, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued the much anticipated rules aimed at restricting China’s ability to obtain advanced computing chips, develop and maintain supercomputers, and manufacture advanced semiconductors (“Rule”) (87 FR 62186). In addition to formalizing the licensing requirements included in the recent BIS “is informed” letters issued to certain US companies on related matters, the Rule imposes a wide range of new and enhanced restrictions…
On September 9, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “2022 IFR”) revising the Export Administration Regulations (“EAR”) to authorize the release of certain technology and software in the context of “standards-related activity” involving entities listed on the Entity List. Comments on the impact of this action on participation in “standards-related activity” must be submitted to BIS no later than November 8, 2022. By…