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Eunkyung Kim Shin

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Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…

On February 2, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued seven new Frequently Asked Questions (“FAQs”) (FAQs 957 through 963) and on February 25, 2022, issued General License 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan” (“GL 20”) to expand authorizations for commercial and financial transactions in Afghanistan and seven new FAQs (FAQs 991 through 997). OFAC also made updates to FAQs to account for the new…

On April 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added two of Russia’s largest banks, Public Joint Stock Company Sberbank of Russia (“Sberbank”) and Joint Stock Company Alfa Bank (“Alfa-Bank”), and their subsidiaries to the Specially Designated Nationals and Blocked Persons List (“SDN List”). OFAC also issued 3 new and 3 amended Russia-related General Licenses, and added several other parties to the SDN List. President Biden also issued…

On March 18, 2022 and in response to Russia’s invasion of Ukraine, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) publicly identified 100 commercial and private aircraft that have recently flown into Russia in apparent violation of the Export Administration Regulations (“EAR”). As summarized in our prior blog posts (see here and here), the US has also issued restrictions that effectively ban any aircraft with a nexus to Russia from using US…