On January 16, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) related to advanced computing integrated circuits (“ICs”) designed to protect US national security and assist foundries and Outsourced Semiconductor Assembly and Test (“OSAT”) companies in complying with provisions of the US Export Administrations Regulations (“EAR”). The IFR builds on previous waves of semiconductor export controls published in October 2022, October 2023, April 2024, and December…
On December 13, 2024, the US Treasury Department (“Treasury”) issued 35 new questions and answers (“FAQs”) providing guidance on the November 17, 2024 final rule outlining the US government’s Outbound Investment Security Program (“Outbound Investment Rules”). 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…
On October 11, 2024, the Office of Foreign Assets Control (“OFAC”) issued a determination under Section 1(a)(i) of Executive Order 13902 dated January 10, 2020 (“EO 13902”) designating the petroleum and petrochemical sectors of the Iranian economy as subject to US secondary sanctions. This industry sector designation adds to secondary sanctions designations announced in January 2020 under EO 13902 on the Iranian construction, mining, manufacturing, and textile sectors of the Iranian economy as well as…
The US Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued an interim final rule to extend OFAC’s recordkeeping requirements for certain transactions from 5 to 10 years. This development mirrors the recent extension of the statute of limitations for civil and criminal violations of the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) to 10 years. Civil enforcement actions brought by OFAC for violations of IEEPA or…