On March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Sanctions Advisory to raise awareness of potential sanctions risks arising from sham transactions used to evade sanctions. The advisory presents examples and lists red flags that may indicate the presence of a sham transaction. While it is explanatory only and does not have the force of law, the advisory follows several recent enforcement actions involving blocked persons…
Following the Trump Administration’s removal of tariffs on products of India for “buying Russian oil” in February, the Office of Foreign Assets Control (“OFAC”) has issued a temporary general license to authorize transactions that are “ordinarily incident and necessary to the sale, delivery, or offloading of” Russian crude oil and petroleum products to companies in India. General License 133 authorizes certain transactions involving the sale, delivery or offloading of Russian crude oil or petroleum products…
The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued a final rule, effective January 15, 2026, revising the license review policy for exports from the United States of certain commercially available advanced computing semiconductors to end users in China and Macau—moving from a presumption of denial to case‑by‑case review under certain conditions. The case-by-case review policy is only available for exports meeting strict requirements, including various certifications as to sufficient supply…
On January 12, 2026, the US House of Representatives passed the Remote Access Security Act (H.R. 2683), which would amend the Export Control Reform Act of 2018 (“ECRA”) to authorize the extension of existing export controls to the remote access of US goods, software, or technology, if a determination is made that “the use of the item could pose a serious risk to the national security or foreign policy of the United States.” The House…