On September 18, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the expiration of the national emergency declared in Executive Order 14046 of September 17, 2021, “Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia” (“EO 14046”), and removed persons designated under that order from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Concurrently, the US Department of State published…
The US Department of State has issued a final rule amending the International Traffic in Arms Regulations (“ITAR”) at 22 CFR § 126.1 to remove the embargo on defense trade with Cambodia, following its announcement effective October 26, 2025 that it would review ITAR license applications for Cambodia on a case-by-case basis (see here and here). Cambodia had been subject to a US arms embargo since December 2021, as discussed in our previous blog post. …
In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world. The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: “I will be ordering the cessation of sanctions against Syria…
On September 3, 2024, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) issued revised Guidance for U.S. Persons Abroad (“USPABs”) Authorization Requests (“USPAB Guidance”) and updated FAQs on Defense Services and USPABs. Under the International Traffic in Arms Regulations (“ITAR”), all USPABs need DDTC authorization before they can furnish ITAR-controlled defense services to any foreign person, including USPABs’ non-US employers. The principal changes to the USPAB Guidance are as follows: