On Friday, May 16, 2025, the US Treasury Departmentâs Office of Foreign Assets Control (âOFACâ) and Switzerlandâs State Secretariat for Economic Affairs (âSECOâ) issued a joint Memorandum of Understanding (âMOUâ) in regard to the United States and Switzerlandâs commitment to collaborate and share information related to sanctions and enforcement which was signed on May 9, 2025. The notice is published on OFACâs website here. The MOU provides that information sharing between the United States and…
On December 13, 2024, the US Treasury Department (âTreasuryâ) issued 35 new questions and answers (âFAQsâ) providing guidance on the November 17, 2024 final rule outlining the US governmentâs Outbound Investment Security Program (âOutbound Investment Rulesâ). Â These Outbound Investment Rules, which become effective January 2, 2025, implement a targeted outbound investment compliance regime called for by Executive Order (EO) 14105 issued by President Biden on August 9, 2023. The full list of published FAQs can…
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…