In a new rule announced on January 23, 2024, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) has (i) expanded the scope of the Russian and Belarusian Industry Sector Sanctions under the Export Administration Regulations (“EAR”); (ii) revised restrictions aimed at preventing Iran from supplying unmanned aerial vehicles (“UAVs”) (i.e., drones) to Russia; (iii) expanding the scope of items for which there is no de minimis level of certain US-origin items incorporated…
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 12, 2024,…
On December 11, 2023, the US Departments of Commerce, the Treasury, Justice, State, and Homeland Security issued a “Quint-Seal” Compliance Note titled Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation (“Note”). The Note is directed at the maritime and other transportation industries—including transportation companies, maintenance companies, insurance providers, financial institutions, and “other entities involved in funding and facilitating the transport of…
On December 7, 2023, Chairman Michael McCaul of the Foreign Affairs Committee in the House of Representatives released a 90-Day Review Report (the “Report”) of the US Bureau of Industry and Security (“BIS”), the agency tasked with administering the Export Administration Regulations (15 C.F.R Parts 730–774, the “EAR”) under the US Commerce Department. Chairman McCaul previously highlighted his plans for greater oversight of BIS at an October 2022 Atlantic Council event during which he stated…