On July 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued three Russia-related General Licenses (“GLs”) and issued one new one. OFAC also amended FAQs 967, 1,039, and 1,040, with changes mostly relating to updates made within the GLs. OFAC also issued a new fact sheet on “Russia Sanctions and Agricultural Trade.” GL 6B was amended to broaden the scope of authorized activities in three ways: (i) to broaden…
On May 26, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) updating the scope of License Exceptions Authorized Cybersecurity Exports (“ACE”) and Encryption Commodities, Software, and Technology (“ENC”) related to cybersecurity items in response to public comments on the interim final rule related to cybersecurity items published on October 21, 2021. The interim final rule established a new control on certain cybersecurity items for…
Accounting, Trust and Corporate Formation, and Management Consulting Services Ban On May 8, 2022, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”), in consultation with the US Department of State, issued a Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“EO 14071 Determination”) determining that the prohibitions under Section (1)(a)(ii) of Executive Order (“EO”) 14071 (our previous blog regarding EO 14071 can be found here) shall apply to accounting, trust and…
On April 14, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it had added an additional ten aircraft to its list of aircraft that have recently flown into Belarus or Russia in apparent violation of the Export Administration Regulations (“EAR”) (the “List”). Among these 10 aircraft are seven Belarusian owned/operated commercial aircraft. BIS also revised the tail numbers of 32 aircraft already on the List to account for the…