The US Department of Commerce’s Bureau of Industry and Security (“BIS”) has issued two proposed rules amending the Export Administration Regulations (“EAR”) 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…
On June 24, 2024, the EU adopted its 14th Russia sanctions package, including by amending Council Regulation (EU) 833/2014 (the “EU Russia Sanctions”), effective from June 25, 2024. The amending regulation is accessible here. The 14th package introduced several additional restrictions across different sectors, including: The strengthening of measures designed to prevent the circumvention of EU sanctions is likely to be particularly wide-ranging, impacting businesses outside Russia with indirect exposure to Russia and placing certain…
On June 5, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Syrian Sanctions Regulations (“SSR”), 31 C.F.R. Part 542 and issued and amended frequently asked questions (“FAQs”) related to the SSR. According to a new OFAC FAQ, these changes are aimed, in part, at facilitating humanitarian assistance and internet-based communication services to Syrian civilians. The SSR has been revised as follows: OFAC also issued one new SSR FAQ…
The sanctions enforcement storm is underway. As we highlighted in the introduction to this blog series, the quickly evolving sanctions landscape of recent years has increased the complexity of compliance. Keeping up with ever-changing multi-jurisdictional sanctions and adapting compliance practices has proven challenging for companies with complex operations and supply chains. Instances of non-compliance can be inevitable. A company’s investigation triage plan should evaluate mandatory disclosure obligations and, if there are none, the availability and…