On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russiaās continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russiaās military-industrial base, the US…
On 24 September 2024, the G7 Sub-Working Group on Export Control Enforcement, which comprises representatives from the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (the āG7ā), published the first-ever joint guidance for industry on preventing evasion of export control and sanctions imposed on Russia (āJoint Guidanceā). The stated goal of the Joint Guidance is to assist industry in identifying Russiaās evolving evasion tactics and in complying with multilateral…
On September 3, 2024, the US Department of Stateās Directorate of Defense Trade Controls (āDDTCā) issued revised Guidance for U.S. Persons Abroad (āUSPABsā) Authorization Requests (āUSPAB Guidanceā) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (āITARā), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABsā non-US employers. The principal changes to the USPAB Guidance are as follows:
The US Department of Commerceās Bureau of Industry and Security (āBISā) has issued two proposed rules amending the Export Administration Regulations (āEARā) to impose expansive new controls on US personsā activities in connection with non-US military, security, and intelligence end users and end uses, as well as new end user-, end use-, and list-based controls applicable to items subject to the EAR. These new controls would apply to more categories of activities and end users/end…