Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…
On July 10, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”), providing enhanced favorable treatment to the United Arab Emirates (“UAE”) under the Export Administration Regulations (“EAR”). BIS indicates the change is a recognition of the UAE’s status as a US Major Defense Partner, its key role in advancing US national security interests including during Operation Epic Fury, its commitment to implementing effective export…
On June 11, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published in the Federal Register the List of Medical Devices Requiring Specific Authorization under the North Korea Sanctions Regulations, 31 CFR Part 510 (“NKSR”). The export or reexport of these excluded non-US medical devices to North Korea requires a specific license from OFAC if US Persons are involved. Other non-US medical devices remain eligible for export/reexport to North Korea…
On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…