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Eunkyung Kim Shin (US)

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OFAC Issues Russian Crude Oil-related Determination, Guidance on Implementation of the Price Cap Policy for Russian Crude Oil, and Russia-related General Licenses

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On November 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new determination pursuant to Executive Order 14071 of April 6, 2022 (“EO 14071”) – “Determination Pursuant to Section 1 (a)(ii) of EO 14071” (“Determination”). The Determination implements the price cap policy for Russian crude oil, as anticipated based on OFAC’s September 2022 preliminary guidance related to the implementation of the policy banning the provision of services related to…

BIS Issues New Export Controls Targeting China’s Advanced Computing and Semiconductor Sectors

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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…

OFAC Issues Updated Iran General License Related to Certain Services, Software, and Hardware for Communications over the Internet and New Related FAQs

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On September 23, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued Iran General License D-2 (“GL D-2”), which amends and replaces the former Iran General License D-1 (“GL D-1”), and published three related Frequently Asked Questions (“FAQs”). GL D-2 authorizes a more expansive set of internet communication-related activities, including cloud-based software and services, that are otherwise prohibited under the Iranian Transactions and Sanctions Regulations (“ITSR”). According to the accompanying…

OFAC Issues Preliminary Guidance on the Implementation of a Maritime Services Policy Ban and Related Price Exception for Seaborne Russian Oil

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Following the G7 Finance Ministers Meeting on September 2, 2022 (see our previous blog here), on September 9, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued preliminary guidance on implementation of the policy banning the provision of services related to the maritime transportation of (i) Russian-origin crude oil and (ii) Russian-origin petroleum products (together “seaborne Russian oil”) (the “Maritime Services Policy”).  The ban under the Maritime Services Policy will…

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