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…
On August 18, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued new FAQs addressing (i) certain red flags related to compliance concerns and potential evasion of the Russia- and Belarus-related export controls and sanctions, and (ii) key red flags that semiconductor foundries should consider when potentially dealing with parties on the Entity List. We summarize key points from these new FAQs below, the full text of which are available here and here. …
Following initial announcements last year, on July 20, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published two Open General Licenses (“OGLs”) permitting certain reexports and retransfers to certain parties under the International Trade in Arms Regulations (“ITAR”). The OGLs, which are part of a DDTC pilot program, will be valid for one year, effective from August 1, 2022 through July 31, 2023. The related DDTC fact sheet can be found…
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…