- More than 500 entities and individuals added to the Specially Designated Nationals and Blocked Persons List and nearly 100 added to the Entity List.
- Four new or updated general licenses issued by the Office of Foreign Assets Control to address wind-down and safety considerations.
- An expansion of the multilateral Common High Priority Items
National Defense Authorization Act for Fiscal Year 2024 Adds Significant Trade Provisions
President Biden signed the National Defense Authorization Act for Fiscal Year 2024 into law (P.L. 118-31) (NDAA 2024 or Act) in December 2023. Lawmakers frequently target this type of “must pass” legislation as a vehicle to codify their own, often unrelated policy priorities or “rider” provisions. The NDAA 2024 is no exception, containing a patchwork
U.S. Imposes New Sanctions on Russia to Commemorate Second Anniversary of Russia’s Invasion of Ukraine
On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added
OFAC Extends Authorizations Under Updated Russia General License 83A
On February 20, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended Russia-related General License (GL) 83 by issuing a revised version: GL 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.” The modified GL 83A maintains the
Treasury Releases Semi-Annual List of Countries Requiring Cooperation With International Boycotts
In addition to its role in enforcing U.S. export control laws, the Department of Commerce’s Bureau of Industry and Security (BIS) is charged with administering and enforcing the antiboycott laws under the Export Administration Act. These antiboycott laws were adopted to encourage and, in some circumstances, require U.S. companies to refuse to participate in foreign
OFAC Issues Determinations to Prohibit Import of Russian-Origin Diamonds
On December 22, 2023, President Joseph Biden amended Executive Order (EO) 14068 by additionally authorizing the prohibition on the importation and entry into the United States of diamonds of Russian Federation origin. See Thompson Hine Update of January 2, 2024. The EO required that such a ban be implemented only after the issuance of
OFAC Issues Oil Price Cap Compliance and Enforcement Alert Recommending Methods to Mitigate Evasion Risks
On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the
U.S. Announces New Sanctions to Promote Peace, Security, and Stability in the West Bank
On February 1, 2024, the United States introduced new sanctions to promote peace in the West Bank, targeting recent actions that jeopardize the region’s stability, including attacks by Israeli settlers against Palestinians and Palestinian attacks against Israelis. This follows the related visa restriction policy announced by the State Department on December 5, 2023.
The sanctions have
United States to Reinstate Certain Sanctions on Venezuela
On January 30, 2024, the Department of State announced in a press release that the United States would be reinstating certain sanctions actions on Venezuela in light of recent activities by President Nicolás Maduro and his regime, including the recent barring of opposition candidates from competing in Venezuela’s 2024 presidential election.
In October 2023, the
BIS Issues Policy Memo on the Voluntary Self-Disclosure Process
- 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