On November 26, 2024, the US Commerce Departmentâs Bureau of Industry and Security (âBISâ) issued a final rule (âFinal Ruleâ) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (âCCLâ) that are subject to the Export Administration Regulations (âEARâ). This expansion of controls is intended to address BISâ concern that certain CCL items that are not currently controlled for Pakistan have…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russiaâs continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russiaâs military-industrial base, the US…
On October 9, 2024, the US Commerce Departmentâs Bureau of Industry and Security (âBISâ) issued guidance to financial institutions on best practices for compliance with the US Export Administrations Regulations (âEARâ). The guidance aims to help financial institutions minimize the inadvertent EAR violations, especially under General Prohibition 10 (âGP 10â), which prohibits financing or servicing items subject to the EAR with knowledge that a violation of the EAR has occurred, is about to occur, or…
The US Department of Commerceâs Bureau of Industry and Security (âBISâ) issued an interim final rule (the “IFR”) on September 6, 2024 that imposes new “plurilateral” worldwide licensing controls on certain advanced technologies, including certain quantum, semiconductor-related and additive manufacturing items, under new and amended ECCNs in the Export Administration Regulations (the “EAR”), introduces a new license exception for certain items to allied countries implementing equivalent controls, adds two new general licenses for certain Gate…