Author

Michael Amberg (UK)

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The US Department of Commerce’s Bureau of Industry and Security (ā€œBISā€) has issued two proposed rules amending the Export Administration Regulations (ā€œEARā€) to impose expansive new controls on US persons’ 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…

The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…

On February 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (ā€œOFACā€) issued a Compliance CommuniquĆ© containing Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People (ā€œGuidanceā€). The Guidance follows the January 17, 2024 announcement of the redesignation of Ansarallah (or Ansar Allah), commonly known as the Houthis, as a Specially Designated Global Terrorist (ā€œSDGTā€) , which became effective on February 16, 2024. The same day,…

In a new rule announced on January 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (ā€œBISā€) has (i) expanded the scope of the Russian and Belarusian Industry Sector Sanctions under the Export Administration Regulations (ā€œEARā€); (ii) revised restrictions aimed at preventing Iran from supplying unmanned aerial vehicles (ā€œUAVsā€) (i.e., drones) to Russia; (iii) expanding the scope of items for which there is no de minimis level of certain US-origin items incorporated…