The US Department of Commerce (“Department”) issued a final rule (the “Rule”) on December 6, 2024 to amend provisions related to the Department’s review of transactions involving information and communications technology and services (“ICTS”) “designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary that may pose undue or unacceptable risk to the United States or U.S. persons.” The Rule implements important clarifications…
On October 11, 2024, the Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order 13902 dated January 10, 2020 (“EO 13902”) designating the petroleum and petrochemical sectors of the Iranian economy as subject to US secondary sanctions. This industry sector designation adds to secondary sanctions designations announced in January 2020 under EO 13902 on the Iranian construction, mining, manufacturing, and textile sectors of the Iranian economy as well as…
On 24 September 2024, the G7 Sub-Working Group on Export Control Enforcement, which comprises representatives from the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (the “G7”), published the first-ever joint guidance for industry on preventing evasion of export control and sanctions imposed on Russia (“Joint Guidance”). The stated goal of the Joint Guidance is to assist industry in identifying Russia’s evolving evasion tactics and in complying with multilateral…
On August 15, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published the long-awaited final rule (“Final Rule”), effective September 16, 2024, expanding the definition of “activities that are not exports, reexports, retransfers, or temporary imports” pursuant to Section 120.54 of the International Traffic in Arms Regulations (“ITAR”). Please see our previous blog here when DDTC issued a proposed rule (“Proposed Rule”) to make these changes. The Final Rule adds…