On May 10, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued an interim final rule (“IFR”), effective on August 8, 2024, amending the Reporting, Procedures and Penalties Regulations under 31 CFR 510 (the “Regulations”). The IFR includes revisions and clarifications to certain procedures and reporting requirements related to certain OFAC submissions, including reports of blocked property and rejected transactions. In particular, the IFR implements the following revisions and clarifications:…
On March 21, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule (“Final Rule”) revising and expanding the end-user controls under Part 744 of the Export Administration Regulations (“EAR”). Specifically, the Final Rule expanded end-user controls applicable to certain persons identified on the List of Specially Designated Nationals and Blocked Persons (“SDN List”) maintained by the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) under various sanctions…
On February 1, 2024, President Biden issued Executive Order 14115 (“EO 14115”) targeting persons involved in activities that threaten the peace, security, and stability in the West Bank. Meanwhile, the UK government announced on 12 February 2024 sanctions on “extremist Israeli settlers” who have committed human rights abuses against Palestinian communities. Pursuant to EO 14115, four individuals were added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Treasury Department’s…
On April 18, 2023, Matthew S. Axelrod, the Assistant Secretary for Export Enforcement, US Department of Commerce’s Bureau of Industry and Security (“BIS”), issued a memorandum titled “Clarifying Our Policy Regarding Voluntary Self-Disclosures and Disclosures Concerning Others” (the “VSD Policy Memorandum”) to clarify and announce BIS’ policies concerning voluntary self-disclosures (“VSDs”) of Export Administration Regulations (“EAR”) violations and disclosures of possible EAR violations committed by third parties. The VSD Policy Memorandum builds on Assistant Secretary…