Author

Kerry B. Contini

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Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…

On January 5, 2023, the US and Turkish governments took joint action imposed sanctions targeting four individuals and two entities determined to be associated with the financial facilitation network of the Islamic State of Iraq and Syria (“ISIS”). See here for the US action and here for the Turkish action. The designations target the Islamic State group’s head of foreign financing, Abd Al Hamid Salim Ibrahim Ismail Brukan al-Khatuni, and his network coordinated by his sons.…

On December 3, 2022, G7 members formally set the highly anticipated price cap on Russian oil at 60 USD per barrel. This price cap applies to crude oil, petroleum oils, and oils obtained from bituminous minerals which originate in or are exported from Russia. Below we summarize (1) some of the key aspects of the G7’s price cap, and (2) the measures taken to implement the price cap by the EU,US, UK, Japan and Canada.…

On November 10, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) reissued Russia-related General License 8D, “Authorizing Transactions Related to Energy.” The scope of the General License did not change since the previous reissuance; however, transactions “related to energy” with the list of entities listed in the General License are now authorized through 12:01 a.m. eastern standard time, May 15, 2023. General License 8D authorizes transactions “related to energy” with: (i) State…