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Bart M. McMillan

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On August 23, 2023, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the first Determination Pursuant to Section 1(a)(i) of Executive Order (“EO”) 14014 (the “Determination”), which extends the application of section 1(a)(i) of EO 14014 to the jet fuel sector of the Burmese economy. On the same day, OFAC also published two related Frequently Asked Questions (“FAQs”): FAQ 1132 and FAQ 1133. Our blog post on the issuance of EO 14014…

On June 27, 2023, the US Departments of State, the Treasury, Labor, Commerce, and Homeland Security, and the United States Agency for International Development issued a joint advisory — the Africa Gold Advisory (“Advisory”) — that (i) highlights the opportunities and specific risks raised by the gold trade across sub-Saharan Africa and (ii) encourages industry participants to adopt and apply strengthened due diligence practices to guard against such risks. The Advisory states that it was…

On May 19, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) implemented further economic sanctions and export controls targeting Russia and Belarus. The OFAC press release and BIS press release both underscore the US Government’s close coordination with international partners and allies to align new restrictions on Russia and Belarus. In addition, the Leaders of the G7 released…

On March 30, 2023, the White House and US Department of Commerce’s Bureau of Industry and Security (“BIS”) announced human rights and export control measures that underscore the US Government’s focus on human rights as a matter of foreign policy. The White House announcement is available here. The BIS announcement is available here. The White also issued a Fact Sheet that includes these announcements and other sanctions and export control provisions. White House: Export Controls…