On March 20, 2026, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Iran-related General License U (“GL U”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Iranian-Origin Loaded on Vessels as of March 20, 2026.” One day earlier, on March 19, 2026, OFAC issued Russia-related General License 134A (“GL 134A”), “Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on…
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…
On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export Administration Regulations (“EAR”). This marks a major shift in US export control policy by automatically extending certain EAR end user…