On January 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 24 (“GL”), which authorizes certain transactions formerly prohibited by several US sanctions programs. OFAC also issued eight new Syria Frequently Asked Questions (“FAQs”) and amended one existing FAQ, as part of its effort to ease certain trading restrictions after rebel forces toppled Syrian President Bashar al-Assad’s regime on December 8, 2024. General License No. 24 This…
On December 13, 2024, the US Treasury Department (“Treasury”) issued 35 new questions and answers (“FAQs”) providing guidance on the November 17, 2024 final rule outlining the US government’s Outbound Investment Security Program (“Outbound Investment Rules”). These Outbound Investment Rules, which become effective January 2, 2025, implement a targeted outbound investment compliance regime called for by Executive Order (EO) 14105 issued by President Biden on August 9, 2023. The full list of published FAQs can…
On October 30, 2024, the US Government imposed sanctions on hundreds of entities and individuals across the globe, primarily in response to Russia’s continued war in Ukraine, and amended US export controls related to Russia and Belarus. Below, we describe the key actions taken by the US Departments of the Treasury, State, and Commerce. 1. OFAC Actions With the aim of disrupting global sanctions evasion networks and domestic suppliers to Russia’s military-industrial base, the US…
On August 23, 2024, the eve of Ukraine’s Independence Day (August 24, 2024), the US Departments of Commerce and Treasury issued new export controls and sanctions in response to Russia’s invasion of Ukraine. The new controls target the procurement networks who support Russia’s war on Ukraine and its military industrial complex and payment channels. The Commerce Department’s Bureau of Industry and Security (“BIS”) made the following changes to the Export Administration Regulations (“EAR”) and…