- The policy memorandum builds upon two previous updates to the VSD process announced in June 2022 and April 2023. It gives direction to companies wishing to take advantage of certain faster processing options for VSDs.
- Cuts some requirements for submissions of minor or technical infractions of U.S. export controls to reduce the administrative
USTR Releases Supplemental Multiagency Business Advisory on Burma
On January 26, 2024, the Office of the U.S. Trade Representative (USTR) released a Supplemental Business Advisory highlighting continued risks and exposure of doing business in Burma. In January 2022, the U.S. Departments of State, the Treasury, Commerce, Homeland Security, Labor and the USTR first published a business advisory on heightened risk of doing business
BIS Implements Additional Sanctions Against Russia and Belarus
Effective January 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded export controls and sanctions against Russia for its continuing aggression against Ukraine and Belarus for its complicity in such activities. In a Final Rule, BIS is expanding the scope of the Export Administration Regulations’ (EAR) Russian and Belarusian
U.S. Re-Designates Ansarallah (aka the Houthis) as a Global Terrorist Group
On January 17, 2024, the Department of State announced that it was re-designating Yemen-based Ansarallah, commonly referred to as the Houthis, as a Specially Designated Global Terrorist (SDGT) group. This designation will be effective as of February 16, 2024, when Ansarallah will be placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC)
OFAC Again Extends Authorizations Under Russia General License 13
On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13H, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2024
As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2024.
Annual Self-Classification Report
The self-classification report covers less sensitive items described under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.,
OFAC Continues to Extend Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On January 16, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5N, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 16, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
CBP to Deactivate Certain Section 232 Exclusions Upon Reaching 95% of Allocated Quantity
On January 5, 2024, U.S. Customs and Border Protection (CBP) issued guidance via its Cargo Systems Messaging Service announcing new thresholds for deactivating Section 232 steel and aluminum product exclusions prior to reaching 100% of the allocated quantity under any granted exclusion. CBP has announced that effective February 15, 2024, for certain types of Section
U.S. International Trade Commission Releases 2024 Harmonized Tariff Schedule Basic Edition
The U.S. International Trade Commission released the 2024 Basic Edition of the Harmonized Tariff Schedule of the United States (HTSUS) on January 1, 2024.
The HTSUS sets out the tariff rates and statistical categories for all merchandise imported into the United States and is based on the international Harmonized System, which is the global system
OFAC Updates its Guidance on the Price Caps on Russian Oil and Russian Petroleum Products
On December 20, 2023, nearly eleven months after publishing its finalized guidance on the implementation of the twin price caps on Russian oil and Russian petroleum products, the Department of the Treasury (“Treasury”) published a revised Guidance on Implementation of the Price Cap Policy for Crude Oil and Petroleum Products of Russian Federation Origin.