On September 15, 2022, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) to expand the existing sanctions against Russia and Belarus under the Export Administration Regulations (“EAR”). The purpose of the Final Rule is to “protect U.S. national security and foreign policy interests by further restricting Russia’s access to items that it needs to support its military capabilities.” The Final Rule took effect on September…
Following initial announcements last year, on July 20, 2022, the US Department of State’s Directorate of Defense Trade Controls (“DDTC”) published two Open General Licenses (“OGLs”) permitting certain reexports and retransfers to certain parties under the International Trade in Arms Regulations (“ITAR”). The OGLs, which are part of a DDTC pilot program, will be valid for one year, effective from August 1, 2022 through July 31, 2023. The related DDTC fact sheet can be found…
On June 6, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new and amended Frequently Asked Questions (“FAQs “) regarding the Russian investment ban imposed under Executive Orders 14066, 14068, and 14071 (collectively, the “Investment Ban EOs”). Our prior blog posts on these Investment Ban EOs can be found here and here. These new and amended FAQs define the term “new investment” used in the Investment Ban EOs and…
On May 9, 2022, the US Department of Commerce issued a Final Rule (the “Final Rule”) expanding the Russian industry sector sanctions to cover additional items subject to the Export Administration Regulations (the “EAR”) beyond restrictions targeting the Russian energy sector. Under the Russia industry sector sanctions, all items identified in Supplement No. 4 to part 746 of the EAR (“Supplement No. 4”) that are subject to the EAR trigger a licensing requirement when they…