On Wednesday, August 13, 2014, the US Office of Foreign Assets Control (“OFAC”) issued “Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked” (the “revised guidance”). This revised guidance is effective today, August 14, 2014, pursuant to its publication in the Federal Register. This revised guidance replaces previous guidance that OFAC issued on this topic on February 14, 2008 (the “previous guidance”). U.S. Persons are prohibited from dealing, directly…

Further to our post on 26 March concerning US BIS’ announcement that it had put on hold the issuance of licences for exports/reexports of items to Russia since 1 March 2014, the US DDTC has made a similar announcement on its main webpage. Until further notice, the US DDTC has put on hold the issuance of licences that would authorise the export of defence articles and defence services to Russia. This notice is available here:…