On September 29, 2025, after some months of speculation, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule “Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities” (the “IFR”). The IFR immediately introduces a new “Affiliates Rule,” essentially a “50% ownership flow-down rule,” into the Export Administration Regulations (“EAR”). This marks a major shift in US export control policy by automatically extending certain EAR end user…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s 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 Russia’s military-industrial base, the US…
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…
On September 30, 2022, the US Government imposed additional sanctions against Russia in response to Russia’s annexation of the Ukrainian provinces of Donetsk, Kherson, Luhansk, and Zaporizhzhya following referenda. New SDN Designations and OFAC FAQ The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced hundreds of new Russia-related designations to the Specially Designated Nationals and Blocked Persons List (“SDN List”). According to an accompanying press release, the designations include 14 individuals…