On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued an updated ransomware advisory (“Updated Advisory”) highlighting the sanctions risks associated with ransomware payments in connection with malicious cyber-enabled activities and the proactive steps companies can take to mitigate such risks, including actions that OFAC would consider to be “mitigating factors” in any related enforcement action. OFAC concurrently designated SUEX OTC, S.R.O. (“SUEX”) as a Specially Designated National (“SDN”), the first…
On July 12, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Venezuela General License 40 (“GL 40”), “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” OFAC concurrently issued related FAQs (FAQ 914 and FAQ 915). Our previous blog posts about US sanctions targeting Venezuela are available here. GL 40 authorizes US persons to engage in transactions and activities through July 7, 2022 related to the…
On June 9, 2021, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule, effective June 8, amending the Export Administration Regulations (“EAR”) to reflect the formal termination by the United Arab Emirates (“UAE”) of its participation in the Arab League Boycott of Israel (the “Amendment”). This means that certain requests for information, action or agreement from the UAE will no longer be presumed to be boycott-related if made after…
On March 29, 2021, the Commerce Department published an advance notice of proposed rulemaking (“ANPRM”) seeking public comment on potential licensing or other pre-clearance processes for transactions under the regulations that took effect on March 22, 2021 to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (“Executive Order 13873”). Executive Order 13873 authorizes the Commerce Department to block or impose conditions on transactions involving information and communications technology and…