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Meghan Hamilton

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On March 24, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending and reissuing the Belarus Sanctions Regulations, 31 CFR part 548 (the “Regulations”), to implement Executive Order (“EO”) 14038, including Directive 1 issued pursuant to EO 14038. The final rule is effective as of March 27, 2023. OFAC had previously sanctioned certain Belarussian parties as a result of Belarus’ support for and facilitation of Russia’s invasion of…

On March 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new and two reissued General Licenses and issued new and revised Frequently Asked Questions (FAQs). OFAC also added more than 400 parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”). A summary of these developments can be found on OFAC’s Recent Actions page here and here. New and Revised General Licenses OFAC issued two…

On March 8, 2022, the White House issued a new Executive Order, “Prohibiting Certain Imports and New Investments with Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine” (“Energy-Related EO”), that, among other things, bans the import into the United States of certain Russian-origin energy products and new investments in the Russian energy sector. A new import, export, and investment ban on additional Russian sectors will be addressed via…

On March 2, 2022, in response to Belarus’s enabling of Russia’s further invasion of Ukraine, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) effective on the same day, that implements sweeping export controls measures targeting Belarus. This Final Rule subjects Belarus to substantially the same export controls that were imposed on Russia and became effective on February 24, 2022. (Our blog post summarizing those export controls targeting…