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Rob O'Brien (US)

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On July 10, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 2 (“GL 2”) under the Democratic Republic of the Congo Sanctions Regulations (the “DRCSR”) as the eastern Democratic Republic of the Congo (“DRC”) continues to face significant humanitarian challenges, including an Ebola outbreak in the region. GL 2 goes beyond the existing general license found in section 547.513 of the DRCSR, which is limited to…

On June 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued three Venezuela-related general licenses and amended FAQ 595. The most notable development is new General License 59 (“GL 59”), which authorizes certain aircraft safety-related activities for Venezuelan Specially Designated National airline, Conviasa. OFAC also reissued its telecommunications and mail authorization as General License 24A (“GL 24A”), again delayed the effectiveness of the PdVSA 2020 bond authorization through General…

On May 31, 2026, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued guidance clarifying that a license continues to be required under the Export Administration Regulations (“EAR”) for exports of advanced computing items to entities located in any country, if those entities are headquartered in Country Group D:5 (including China) or Macau, or have “an ultimate parent company” headquartered in Country Group D:5 or Macau. The BIS Guidance was prompted by…

On April 8, 2026, the US Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint proposed rule (“Proposed Rule”) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act”). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML”) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate…