On May 1, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) and the US Department of State designated nearly 300 individuals, entities, and vessels to the List of Specially Designated Nationals and Blocked Persons (“SDN List”) mainly targeting Russia’s military capacity. On the same day, OFAC also issued three new general licenses (“GLs”) authorizing limited transactions involving certain SDNs. We summarize these developments below. SDN Designations According to OFAC’s press…
The Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”), effective on April 19, 2024, amending the Export Administrations Regulations (“EAR”) to ease most licensing restrictions on exports/reexports to and within Australia and the UK of items subject to the EAR. This is a key change in that export licensing requirements under the EAR for Australia and the UK are now largely similar to those for Canada. The driver for this was…
On January 29, 2024, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) revoked General License 43 (“GL 43”), which authorized certain transactions involving CVG Compania General de Mineria de Venezuela CA (“Minerven”). GL 43 was replaced with GL 43A to allow US Persons, through 12:01 a.m. eastern standard time, February 13, 2024, to wind down transactions involving Minerven (and entities it owns 50% or more) that were previously authorized by GL…
On January 26, 2024, the US Departments of State, Treasury, Commerce, Homeland Security, and Labor, and the Office of the US Trade Representative published a Supplemental Business Advisory (“Supplemental Advisory”) intended to highlight additional high-risk sectors and activities and update guidance for individuals, businesses, financial institutions, and other persons (e.g., investors, consultants, non-governmental organizations, due diligence service providers) regarding continued risks of doing business in Myanmar/Burma. The Supplementary Advisory incorporates significant sanctions developments against Myanmar…