On May 1, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) and the US Department of State designated nearly 300 individuals, entities, and vessels to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) mainly targeting Russia’s military capacity. On the same day, OFAC also issued three new general licenses (“GLs”) authorizing limited transactions involving certain SDNs. We summarize these developments below. SDN Designations According to OFAC’s press…
On March 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released an interim final rule, effective April 4, 2024 (“April 2024 IFR”) to correct inadvertent errors made in prior semiconductor-related rules in the Export Administration Regulations (“EAR”) and further clarify such rules. The April 2024 IFR clarifies the (1) “Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections” (88 FR 73458, October…
On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) revoked General License 43 (“GL 43”), which authorized certain transactions involving CVG Compania General de Mineria de Venezuela CA (“Minerven”). GL 43 was replaced with GL 43A to allow US Persons, through 12:01 a.m. eastern standard time, February 13, 2024, to wind down transactions involving Minerven (and entities it owns 50% or more) that were previously authorized by GL…
On December 22, 2023, the Biden Administration issued a new Executive Order (“EO”) “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (the “December 22 EO”) amending EO 14024 of April 15, 2021 (“Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation”) and EO 14068 of March 11, 2022 (“Prohibiting Certain Imports, Exports, and New Investment With Respect to Continued Russian Federation Aggression”). According to a…