On December 22, 2023, President Joseph Biden issued Executive Order 14114 (EO) amending EO 14024 by authorizing the imposition of U.S. sanctions on foreign financial institutions that are either facilitating significant transactions on behalf of persons designated for operating in certain key sectors of the Russian economy, or facilitating significant transactions or providing services involving Russia’s
President Biden Expands U.S. Sanctions on Russia by Authorizing Additional Prohibitions on Imports of Russian Seafood and Diamonds
On December 22, 2023, President Joseph Biden amended, among other things, Executive Order (EO) 14068, by additionally authorizing the prohibition on the importation and entry into the United States, including a foreign trade zone located in the United States, of the following products of Russian Federation origin: fish, seafood, and preparations thereof, as well
EU Suspends Retaliatory Tariffs on U.S. Imports and U.S. Extends TRQs on Imports of EU Steel and Aluminum as Bilateral Negotiations Continue
The temporary trade truce between the United States and European Union (EU) will continue after the EU issued a press release on December 19, 2023 announcing the customs union would suspend the reimposition of certain retaliatory tariffs on U.S. imports until March 31, 2025. The EU’s retaliatory tariffs, which were scheduled to resume January 1
USTR Again Extends Certain China Section 301 Product Exclusions
On December 29, 2023, the Office of the U.S. Trade Representative (USTR) issued a Federal Register notice further extending certain China-related Section 301 product exclusions through May 31, 2024. This action extends 352 exclusions previously reinstated in December 2022 through September 30, 2023, and 77 COVID-related exclusions previously extended in May 2023 through September 30
Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing Capabilities
- These two Interim Final Rules reinforce the October 7, 2022, controls appended to the EAR to restrict China’s ability to both purchase and manufacture certain high-end chips critical for military advantage.
- The rules impose controls on additional types of semiconductor manufacturing equipment, adjust the parameters that determine whether an advanced computing chip is
Executive Order Issued Restricting U.S. Investments in Chinese Technology; Treasury Seeks Public Comment on Implementation
- A new Executive Order prohibits U.S. investments in semiconductors and microelectronics, quantum information technologies, and artificial intelligence capabilities in China and other countries of concern and imposes certain notification requirements.
- Certain passive and similar investments will be excepted from the restrictions.
- An Advanced Notice of Public Rulemaking seeks public comment on the scope
FinCEN & BIS Issue Joint Alert Encouraging Continued Vigilance Regarding Potential Russia Export Control Evasion
- The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
- The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
- Included is a list of certain “high priority” items organized according to their Harmonized
Commerce Issues Policy Memo to Incentivize More Disclosures of Export Violations
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
OFAC Publishes Alert Warning of Possible Evasion of the Russian Oil Price Cap
On April 17, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Alert warning U.S. persons about possible evasion of the price cap set on Russian-origin oil (see Update of December 5, 2022) and Russian-origin petroleum products (see Update of February 8, 2023) pursuant to Executive
OFAC and State Department Continue to Target Individuals and Entities Facilitating Russian Financial Transactions and Supporting Russia’s Defense Sector
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