On January 2, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…
On November 21, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated dozens of Russian banks, including Gazprombank and other Russian banks, securities registrars, and finance officials, to the List of Specially Designated Nationals and Blocked Persons (“SDN List”). The full SDN designation of Gazprombank, the largest remaining Russian bank, is particularly notable given its role in supporting gas flows between Russia and remaining European and other customers. On the…
On 24 September 2024, the G7 Sub-Working Group on Export Control Enforcement, which comprises representatives from the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union (the “G7”), published the first-ever joint guidance for industry on preventing evasion of export control and sanctions imposed on Russia (“Joint Guidance”). The stated goal of the Joint Guidance is to assist industry in identifying Russia’s evolving evasion tactics and in complying with multilateral…
On July 29, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued a proposed rule (“Proposed Rule”) that would revise the definition of “defense service” and the scope of related controls in the International Traffic in Arms Regulations (“ITAR”). The Proposed Rule was issued following a review by DDTC that identified certain military, cyber, and intelligence services furnished to foreign persons that are not currently controlled or are controlled but for…