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Lise S. Test (US)

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On August 26, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a final rule removing the Syrian Sanctions Regulations (31 CFR Part 542) from the Code of Federal Regulations (“OFAC Final Rule”). This action follows the issuance of Executive Order (“EO”) 14312 on June 30, 2025, which terminated the national emergency declared in EO 13338 and revoked multiple Syria-related sanctions authorities. Our blog post on the issuance of EO…

On April 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and updated its Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (“the Advisory”), originally issued in September 2019. The updated Advisory is part of OFAC’s implementation of the February 4, 2025 National Security Presidential Memorandum (NSPM-2), which directs the Treasury Department to enact “maximum pressure” on Iran. The Advisory expands on the red flags…

On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an interim final rule (the “IFR”) revising the Export Administration Regulations (“EAR”) to impose new controls on certain biotechnology equipment and related technology. As stated in the IFR, the new controls are necessary to protect against US national security and foreign policy interests “given the dual-use nature and relevance of specific biotechnology equipment to contribute to the research and development…

On January 10, 2025, in a multilateral sanctions action, the US, Canada, EU, and UK sanctioned various Venezuelan individuals linked to the Venezuelan government and prominent state-owned entities. US Sanctions The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated eight Venezuelan individuals as Specially Designated Nationals pursuant to Executive Order 13692, including the president of the Specially Designated National state-owned petroleum company, Petroleos de Venezuela, S.A., (PdVSA), the Venezuelan Ministry of Transportation and…