On February 6, 2025, the US State Department reversed the Biden Administration’s revocation of President Trump’s National Security Presidential Memorandum 5 of June 16, 2017 and recreated the Cuba Restricted List (“CRL” or “List”), which identifies entities and subentities that are controlled by, or acting on behalf of, the Cuban military, intelligence, or security services or personnel. The US State Department also added a Cuban remittance provider to the CRL, effective March 10, 2025. For…
On January 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 24 (“GL”), which authorizes certain transactions formerly prohibited by several US sanctions programs. OFAC also issued eight new Syria Frequently Asked Questions (“FAQs”) and amended one existing FAQ, as part of its effort to ease certain trading restrictions after rebel forces toppled Syrian President Bashar al-Assad’s regime on December 8, 2024. General License No. 24 This…
On November 26, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (“CCL”) that are subject to the Export Administration Regulations (“EAR”). This expansion of controls is intended to address BIS’ concern that certain CCL items that are not currently controlled for Pakistan have…