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Meghan Hamilton

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On June 30, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced four key policy changes to strengthen the administrative enforcement program and tackle external threats. These policy changes prioritize the “most serious violations” and cases that pose the greatest danger to US security. The four policy changes made to the BIS’s Administrative Enforcement Program include: Imposition of Significantly Higher Penalties The most serious administrative violations will trigger more stringent penalties…

On June 2, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added additional Russian and Belarussian entities to the BIS Entity List, enacted new licensing requirements for food, medicine for military end-users on the Entity List, and stated that they would be making charging letters public in a pair of Final Rules (here and here).  We have outlined these developments in additional detail below.   Additions of Russian and Belarusian Entities…

On May 12, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License No. 22 (“GL 22”), authorizing certain activities in particular sectors of the Syrian economy that are otherwise prohibited under the Syrian Sanctions Regulations (31 CFR Part 542, “SSR”) in specified regions of Syria not controlled by the Assad regime. According to the US Statement Department’s press release, GL 22 was issued in support of the Biden Administration’s…

On April 25, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued General License 13R (“GL 13R”) and General License 15L (“GL 15L”), narrowing those authorized activities with GAZ Group and entities owned 50% or more by GAZ Group (“GAZ”), as further described below. OFAC also issued a set of updated FAQs to clarify the scope of authorized activities under these GLs. Our most recent blog post on these GLs is available…