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 15, 2025,…
On January 2, 2025, the US Commerce Department’s Bureau of Industry and Security (“BIS”) published an advance notice of proposed rulemaking (“ANPRM”) seeking public comments to inform the potential development of a rule to safeguard the information and communications technology and services (“ICTS”) supply chain for unmanned aircraft systems (“UAS”), pursuant to the authority of Executive Order 13873. This follows other recent developments in the ICTS regime, including the December 6, 2024 Final Rule amending…
The US Department of Commerce (“Department”) issued a final rule (the “Rule”) on December 6, 2024 to amend provisions related to the Department’s review of transactions involving information and communications technology and services (“ICTS”) “designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a foreign adversary that may pose undue or unacceptable risk to the United States or U.S. persons.” The Rule implements important clarifications…
On November 26, 2024, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Final Rule”) imposing new licensing requirements on exports, reexports, and transfers (in-country) to and within Pakistan of certain items identified on the Commerce Control List (“CCL”) that are subject to the Export Administration Regulations (“EAR”). This expansion of controls is intended to address BIS’ concern that certain CCL items that are not currently controlled for Pakistan have…