On November 2, 2023, the United States government issued new Russia-related sanctions targeting more than 200 individuals and entities. OFAC also issued three new Russia-related General Licenses and reissued another one, and the US Department of Commerce Bureau of Industry and Security (“BIS”) added 13 entities to the Entity List. SDN Designations The US Department of the Treasury Office of Foreign Assets Control (“OFAC”) and the US Department of State added a range of targeted…
In parallel with the new advanced computing, semiconductor, and supercomputing rules issued on October 17, 2023 (here), the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule (“Rule”) amending the Export Administration Regulations (“EAR”) to revise the existing Validated End-User (“VEU”) list of items that are eligible to be supplied to Samsung China Semiconductor Co. Ltd. and SK Hynix Semiconductor (China) Ltd., companies headquartered in the Republic of Korea, for their…
On November 6, 2023, the Department of Commerce’s Bureau of Industry Security (“BIS”) and the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a joint notice (“Joint Notice”) to announce a new Suspicious Activity Report (“SAR”) key term for financial institutions when reporting possible attempts by entities or individuals to evade US export controls. This builds on similar efforts by BIS and FinCEN to require SARs for transactions related to transactions that may…
On October 17, 2023, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) released two interim final rules (collectively, the “October 2023 IFRs” available here and here) amending the Export Administration Regulations (the “EAR”) to further strengthen export controls on advanced computing items, semiconductor manufacturing equipment, and items that can support end uses related to the development and production of supercomputers, advanced-node integrated circuits and semiconductor manufacturing equipment. The long-awaited October 2023 IFRs…