Author

Kerry B. Contini

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On September 8, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued Russia-related General License 13B, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13B”), which amends and replaces the former GL 13A. The authorization of GL 13B is extended through 12:01 a.m. Eastern time on December 7, 2022.  This is the second time an extension has been granted.  GL 13A was previously set to…

On September 2, 2022, the Group of 7 (“G7”) Finance Ministers issued a joint statement confirming their intention to implement a price cap for the purchase of Russian-origin crude oil and petroleum products. The statement says that G7 nations, along with other allies and partners, plan to prohibit the provision of services that enable maritime transportation of such products unless purchased at or below a price level determined by the coalition of countries adhering to…

On August 18, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued new FAQs addressing (i) certain red flags related to compliance concerns and potential evasion of the Russia- and Belarus-related export controls and sanctions, and (ii) key red flags that semiconductor foundries should consider when potentially dealing with parties on the Entity List. We summarize key points from these new FAQs below, the full text of which are available here and here. …

On July 14, 2022, the U.S. House of Representatives passed the National Defense Authorization Act for Fiscal Year 2023 (“NDAA”). One of the amendments included in the House-passed version of the NDAA is a revised version of the “Federal Contracting For Peace And Security Act.” The amendment would prohibit the federal government from entering into, extending, or renewing contracts with contractors that conduct business operations in Russia during its war against Ukraine, with certain exceptions…