The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has amended two Russia-related General Licenses (“GLs”) —131A and 128B—affecting (i) contingent contract negotiations for acquisition of and maintaining/winding down transactions with certain Lukoil entities and (ii) retail transactions with ex-Russia Lukoil service stations. More information regarding each GL is below and our blog post regarding prior iterations of these GLs can be found here. Amended GL 131A On December 10, 2025, OFAC…
We are flagging a recent example of continued coordination on sanctions between the United States, United Kingdom, and Australia focused on cybercrime. On November 19, 2025, the United States, United Kingdom, and Australia jointly imposed sanctions on Russia-based bulletproof hosting (“BPH”) service providers Media Land and ML Cloud and 2 of their key personnel after determining they had supported ransomware operations and other cybercrimes. The US OFAC announcement is here, the UK Government announcement is…
Baker McKenzie’s Global Import Blog published this post on the new trade agreement framework between Switzerland, Liechtenstein, and the United States. Under the framework, the United States will reduce these tariffs to 15%, aligning Switzerland and Liechtenstein with the treatment given to the European Union in exchange for various concessions and commitments made by Switzerland and Liechtenstein. The agreement will also enhance enforcement of trade sanctions and US export controls through closer coordination. In May…
On November 10, 2025, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) formally suspended the implementation of the “Affiliates Rule” for one year, as published in the Federal Register (linked here) on November 12, 2025. This suspension follows high-level trade negotiations between the United States and China, culminating in reciprocal concessions announced in late October and early November as discussed on our blog here and here. Background on the Affiliates Rule Originally…