The US Commerce Department’s Bureau of Industry and Security (“BIS”) has issued a final rule (“Final Rule”), effective July 23, 2024, expanding the jurisdictional scope of the Export Administration Regulations’ (“EAR”) Iran Foreign Direct Product Rule (“Iran FDP Rule”) over more foreign-made items and imposing a licensing requirement for the in-country transfer within Iran of items subject to the EAR under the Iran FDP Rule. This expansion of controls was made to implement the requirements…
On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…
The US Commerce Department’s Bureau of Industry and Security (“BIS”) announced that it is issuing a new License Exception MED that in many cases will eliminate BIS licensing requirements for EAR99 medical devices shipped to and within Russia, Belarus, Crimea, Donetsk People’s Republic (“DNR”), and Luhansk People’s Republic (“LNR”). License Exception MED will go into effect on Monday, April 29. License Exception MED will authorize the export, reexport, and in-country transfer of EAR99 medical devices…
What happened? On January 17, 2024, the US State Department (“State”) announced the designation of Ansarallah, commonly known as the Houthis, as a Specially Designated Global Terrorist (“SDGT”) pursuant to Executive Order 13224. The designation will be effective on February 16, 2024, at which time the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) will add Ansarallah to the list of Specially Designated Nationals and Blocked Persons (“SDN List”). In other words, the designation…