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OFAC

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On May 28, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations (“CACR”) and issued new and updated frequently asked questions (“FAQs”) to further implement a policy originally announced by the Biden Administration on May 16, 2022 to increase support for the Cuban people and private sector entrepreneurs. The CACR has been revised as follows: Clarification and Expansion of Authorized Internet-Based Services and Software: The authorization for…

On the Connect on Tech blog, Justine Phillips, Sylwia Lis, and Alex Lamy have published a post about export control considerations that companies should keep in mind when managing cyber incidents and data exfiltration.  The blog, “Cyber Transparency, Risk & Sanctions: How Cyber Incidents Give Rise to Export Control Issues,” can be found here.

The US and UK introduced new prohibitions last month related to Russian-origin aluminum, copper, and nickel produced on or after April 13, 2024. The US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two determinations imposing new restrictions on the importation of Russian-origin aluminum, copper, and nickel produced on or after to April 13, 2024 (the “Covered Russian Metals”) into the United States, and on the provision by US persons or within…

On May 10, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued an interim final rule (“IFR”), effective on August 8, 2024, amending the Reporting, Procedures and Penalties Regulations under 31 CFR 510 (the “Regulations”). The IFR includes revisions and clarifications to certain procedures and reporting requirements related to certain OFAC submissions, including reports of blocked property and rejected transactions. In particular, the IFR implements the following revisions and clarifications:…