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To increase disclosures of export violations, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a memorandum on April 18, 2023 “clarifying” its enforcement policy related to voluntary self-disclosures of “significant” possible violations of the Export Administration Regulations (EAR). The memo also elaborates upon the policy regarding disclosures of potential EAR violations by

On April 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced further efforts to deny Russia’s access to the international financial system through facilitators and their businesses. For example, OFAC has designated and sanctioned the “facilitation network” of Alisher Burhanovich Usmanov, who had previously been placed on OFAC’s Specially Designated

On March 23, 2023, the Department of the Treasury (“Treasury”) published a Notice of Proposed Rulemaking to implement the Advanced Manufacturing Investment Credit established by the Creating Helpful Incentives to Produce Semiconductors (CHIPS) and Science Act (“CHIPS Act”). The CHIPS Act was enacted in August 2022 to incentivize the manufacture of semiconductors and semiconductor manufacturing

On March 24, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 32 persons and entities to its Unverified List (UVL). The UVL contains the names and addresses of foreign persons who are or have been parties to a transaction involving the export, reexport, or transfer (in-country) of

On the one-year anniversary of Russia’s invasion of Ukraine, President Joseph Biden on February 24, 2023, issued a Proclamation on Adjusting Imports of Aluminum Into the United States to implement: (1) effective March 10, 2023, a 200% import tariff on aluminum articles and derivative aluminum articles that are the products of Russia, and (2) effective

On February 3, 2023, the Department of the Treasury (Treasury) issued multiple determinations related to the price cap to be set on Russian-origin petroleum products. Treasury also published finalized guidance on the broader price cap policy implemented by the “Price Cap Coalition” – an international coalition that includes the United States, the G7, the European Union