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Terence Gilroy

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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…

On September 15, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued (i) two new Determinations under Executive Order (“EO”) 14024; (ii) two new Russia-related General Licenses (“GLs”); (iii) seven new Frequently Asked Questions (“FAQs”) and (iv) five amended FAQs. A press release was issued in tandem with these actions. New Determinations under EO 14024 The new Determination Pursuant to Section 1(a)(i) of Executive Order 14024 expands authorities for the…

On August 2, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) updated its list of aircraft that have flown into Russia or Belarus in apparent violation of the Export Administration Regulations (“EAR”) (the “List”) by adding 25 foreign-produced aircraft. These aircraft were identified by BIS as subject to the EAR because they incorporate controlled US-origin content exceeding applicable de minimis amounts (i.e., greater than 25% by value) and having apparently violated the…

On June 9, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued eleven new Frequently Asked Questions (“FAQs”) (FAQs 1058 – 1068) to provide further guidance on the prohibition on the export of certain services pursuant to Section (1)(a)(ii) of Executive Order (“EO”) 14071 and the Determination Pursuant to Section 1(a)(ii) of Executive Order 14071 (“OFAC Service Ban”).  As detailed in our previous blog post here, the OFAC Service Ban applies to certain…