Author

Terence Gilroy

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On February 16, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a Compliance Communiqué containing Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People (“Guidance”). The Guidance follows the January 17, 2024 announcement of the redesignation of Ansarallah (or Ansar Allah), commonly known as the Houthis, as a Specially Designated Global Terrorist (“SDGT”) , which became effective on February 16, 2024. The same day,…

In a new rule announced on January 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) has (i) expanded the scope of the Russian and Belarusian Industry Sector Sanctions under the Export Administration Regulations (“EAR”); (ii) revised restrictions aimed at preventing Iran from supplying unmanned aerial vehicles (“UAVs”) (i.e., drones) to Russia; (iii) expanding the scope of items for which there is no de minimis level of certain US-origin items incorporated…

On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…

On November 6, 2023, the Department of Commerce’s Bureau of Industry Security (“BIS”) and the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a joint notice (“Joint Notice”) to announce a new Suspicious Activity Report (“SAR”) key term for financial institutions when reporting possible attempts by entities or individuals to evade US export controls. This builds on similar efforts by BIS and FinCEN to require SARs for transactions related to transactions that may…