After much anticipation, on November 5, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released a final rule formally extending the suspension of the “Affiliates Rule” through January 10, 2027. This final rule is due to be published in the Federal Register on November 9, 2026. The Affiliates Rule, originally issued as an interim final rule effective September 29, 2025, automatically extends Entity List, Military End-User List, and certain sanctions-based licensing…
On October 9, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) added the entire International Criminal Court (“ICC”) to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to Executive Order 14203 (“EO 14203”) and issued four general licenses authorizing specified transactions involving the court. Designation of the ICC Under EO 14203 OFAC has designated the ICC under section 1(a)(ii)(A) of EO 14203. The ICC designation follows OFAC’s…
Earlier this month, as part of Operation Economic Outcast targeting Iran, the US Department of the Treasury ushered in a flurry of administrative and regulatory changes. On September 10, 2026, the Office of Foreign Assets Control (“OFAC”) modified its Iran-related specific licensing policy, announced a settlement agreement, and updated the Specially Designated Nationals and Blocked Persons List (“SDN List”). These changes landed two days after OFAC’s September 8, 2026 action against Iran’s aviation sector, which…
On July 17, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced certain updates and changes to its Hong Kong-related sanctions program following the expiration of the national emergency declared in Executive Order (“EO”) 13936, The President’s Executive Order on Hong Kong Normalization. Key changes include: What Changed? OFAC explained that the expiration of EO 13936 does not affect the continuing validity of either the HKAA or the Hong Kong…