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…
On February 17, the Bureau of Industry and Security (“BIS”) in the US Commerce Department announced that it is expediting the processing of export license applications for items needed to aid survivors of the earthquakes in Türkiye and Syria through NGOs. While most items subject to the Export Administration Regulations (“EAR”) do not require licenses for export to Türkiye, Syria is subject to comprehensive US export controls and, as such, items subject to the EAR…
On February 9, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 23, “Authorizing Transactions Related to Earthquake Relief Efforts in Syria.” General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (“SySR”) through 12:01 p.m. eastern daylight time, August 8, 2023. General License 23 does not authorize importation of petroleum or petroleum products of…
The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State (“State”), the US Department of Commerce (“Commerce”), and the US Department of Energy (“DOE”) issued rules adjusting maximum civil monetary penalties (“CMPs”) under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as outlined below. (For additional years of CMPs, see our previous blog post available here.) OFAC CMP Adjustments Under OFAC’s final rule issued on January 13,…