On April 8, 2022, in response to Russia’s ongoing aggression in Ukraine, which has been substantially enabled by Belarus, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) expanding license requirements for Russia and Belarus under the Export Administration Regulations (“EAR”) to all items on the Commerce Control List (“CCL”). The Final Rule also removes license exception eligibility for aircraft registered in, owned or controlled by, or under charter or…
On March 11, 2022, the US Government issued a number of additional sanctions measures against Russia. The latest measures include the issuance of (i) a new Russia-related Executive Order 14068, “Executive Order on Prohibiting Certain Imports, Exports, and New Investment with Respect to Continued Russian Federation Aggression” (“EO 14068”) and (ii) four new General Licenses (“GLs”) related to Russia and Ukraine. These measures include a ban on exports and sales of a range of luxury…
On December 10, 2021, at the Summit for Democracy, the U.S., Australia, Denmark, and Norway, released a Joint Statement announcing an Export Controls and Human Rights Initiative (“the Initiative”) to curb the misuse of technologies by certain governments. The Initiative aims to combat digital authoritarianism in countries where software and advanced surveillance technologies have been used to hack the communications of political opponents and journalists, shape public opinion, and censor information the government deems threatening. In…
On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 (the “General License”) to authorize nongovernmental organizations (“NGOs”) to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria. The General License authorizes NGOs to export/reexport services to Syria in support of not-for-profit activities in Syria, i.e., humanitarian projects…