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Michael Amberg (UK)

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Publication of Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria

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On November 10, 2025, the US Department of the Treasury, US Department of State, and US Department of Commerce issued a Tri-Seal Advisory (see here) summarizing the current scope of US sanctions and export controls relief measures applicable to Syria. The document serves as a consolidated reference point for the actions taken so far to relax US sanctions and export controls for Syria, including those aimed at facilitating humanitarian assistance and early recovery efforts. The…

Commerce Seeks Public Input on the American AI Exports Program

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On October 21, 2025, the US Department of Commerce’s International Trade Administration (“ITA”) announced the implementation of the July 23, 2025 Executive Order (“EO”) Promoting the Export of the American AI Technology Stack (the “American AI Exports Program”). Following our earlier post addressing the White House’s AI Action Plan and the EO, this update focuses on the implementation of the EO and the ITA’s request for public feedback. As a reminder, the EO directs the Secretary…

New DoD Rule Targets Consulting Services Contractors that Also Work With the Governments of China or Russia, State Sponsors of Terrorism, or Certain Sanctioned Entities

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On August 25, 2025, the US Department of Defense (“DoD”) issued a Final Rule amending the Defense Federal Acquisition Regulation Supplement (“DFARS”) to prohibit DoD contracting officers from awarding certain consulting services contracts to contractors where they or their subsidiaries or affiliates hold contracts and subcontracts that involve providing “consulting services” to “covered foreign entities” (“CFEs”) unless they implement a conflict-of-interest mitigation plan. The prohibition applies specifically to contracts assigned a North American Industry Classification…

Webinar summary: Russia sanctions – the end of the beginning? – Tuesday 3 June

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As part of the Annual Compliance Conference webinar series, this session explored the evolving global sanctions landscape in relation to Russia, over three years since the first wave of sanctions following the outbreak of war in February 2022. The panel examined the current state of play, recent developments, and what may lie ahead for businesses navigating this complex environment. Sanctions developments:Speakers provided updates on the 17th EU sanctions package (May 2025), including measures targeting the…

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