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Yu (Iris) Zhang

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On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…

On June 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new and amended Frequently Asked Questions (“FAQs “) regarding the Russian investment ban imposed under Executive Orders 14066, 14068, and 14071 (collectively, the “Investment Ban EOs”). Our prior blog posts on these Investment Ban EOs can be found here and here. These new and amended FAQs define the term “new investment” used in the Investment Ban EOs and…

On May 12, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License No. 22 (“GL 22”), authorizing certain activities in particular sectors of the Syrian economy that are otherwise prohibited under the Syrian Sanctions Regulations (31 CFR Part 542, “SSR”) in specified regions of Syria not controlled by the Assad regime. According to the US Statement Department’s press release, GL 22 was issued in support of the Biden Administration’s…

On April 14, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that it had added an additional ten aircraft to its list of aircraft that have recently flown into Belarus or Russia in apparent violation of the Export Administration Regulations (“EAR”) (the “List”). Among these 10 aircraft are seven Belarusian owned/operated commercial aircraft. BIS also revised the tail numbers of 32 aircraft already on the List to account for the…