On March 2, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”), the US Department of Justice (“DOJ”), and the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a Tri-Seal Compliance Note: Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls (“Compliance Note”) warning the public of efforts to evade Russia-related sanctions and export controls via use of third-party intermediaries and transshipment points. To aid the…
Last week, among the flurry of new sanctions announcements marking the one-year anniversary of Russia’s large-scale invasion of Ukraine, the G7 announced the creation of a new Enforcement Coordination Mechanism “to bolster compliance and enforcement of our measures and deny Russia the benefits of G7 economies.” The International Group of Seven (“G7”) is an intergovernmental forum whose members include the US, UK, Germany, France, Italy, Canada, and Japan, with the European Union as a “non-enumerated”…
On November 26, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued General License 41 (“GL 41“) authorizing Chevron Corporation (“Chevron”) to resume limited oil extraction operations in Venezuela and accompanying FAQs. According to the accompanying press release, OFAC issued GL 41 after Unitary Platform and President Maduro’s regime announced the resumption of negotiations; a humanitarian agreement focused on education, health, food security, flood response, and electricity programs that will…
On October 14, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of State, issued the Russia-related Alert: Impact of Sanctions and Export Controls on Russia’s Military-Industrial Complex (“the Alert”). OFAC also published one new Russia-related frequently asked question (“FAQ”). The Alert outlines impacts of the coordinated sanctions and export controls that have led to shortages of supplies…