On January 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…
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 August 14, 2023, the US State Department, the Labor Department, and the Commerce Department issued a business advisory (“Business Advisory”) highlighting key risks for companies operating in South Sudan. While it does not impose new legal obligations on companies, the Business Advisory highlights the fact that list-based sanctions remain in force targeting certain South Sudanese persons including designations under the US Treasury Department’s Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, and…
On June 16, 2023, the US Commerce Department published a final rule (“Final Rule”), implementing President Biden’s 2021 Executive Order 14034 on “Protecting Americans’ Sensitive Data from Foreign Adversaries,” to amend the Commerce Department’s “Securing the Information and Communications Technology Supply Chain” regulations, 15 C.F.R. Part 7 (“ICTS Regulations”). The amendments mainly relate to connected software applications. The Final Rule was issued in response to comments received to a notice of proposed rulemaking (“NPRM”) issued…