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…
On May 20, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) announced the issuance of a temporary denial order denying the export privileges of the airline Rossiya to participate in transactions subject to the Export Administration Regulations (“EAR”), including exports and reexports from the United States. BIS previously issued similar orders covering Aeroflot, Azur Air, UTair, and Aviastar-TU. Aeroflot is a majority shareholder of Rossiya, and both airlines own and operate a number of US-origin aircraft, many requiring US-origin…
On April 29, 2022 the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the publication of a Final Rule that reissued and renamed the Ukraine-/Russia-Related Sanctions Regulations (“Reissued Regulations”) and updates to related public guidance. Found at 31 C.F.R. Part 589, the Reissued Regulations took effect on May 2 and have been expanded to include a more comprehensive set of regulations, including additional interpretive and definitional guidance, general licenses, and other regulatory…
On March 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new and two reissued General Licenses and issued new and revised Frequently Asked Questions (FAQs). OFAC also added more than 400 parties to the Specially Designated Nationals and Blocked Persons List (“SDN List”). A summary of these developments can be found on OFAC’s Recent Actions page here and here. New and Revised General Licenses OFAC issued two…