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OFAC General License

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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…

On June 5, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Syrian Sanctions Regulations (“SSR”), 31 C.F.R. Part 542 and issued and amended frequently asked questions (“FAQs”) related to the SSR. According to a new OFAC FAQ, these changes are aimed, in part, at facilitating humanitarian assistance and internet-based communication services to Syrian civilians. The SSR has been revised as follows: OFAC also issued one new SSR FAQ…

On June 12, 2024, the US Departments of Treasury and Commerce issued new sanctions and export controls in response to Russia’s continued war in Ukraine. Below we outline key categories of these new and expanded trade measures designed to restrict the flow of support to the Russian military-industrial base. The new sanctions issued by the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) are directed at Russia’s foundational financial infrastructure and access to…