- The final rule took effect September 16. It codifies the series of “policy memoranda” BIS began issuing in 2022 to clarify the agency’s evolving attitude toward voluntary self-disclosures, which in turn aimed to encourage companies, universities and individuals to engage in the process after believing a violation of the Export Administration Regulations, or
OFAC Again Extends Authorizations Under Russia General License 13
On September 30, 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 13K, “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
Department of Commerce Proposes Ban on Connected Vehicles Using Chinese or Russian Hardware and Software
- Proposed rule would prohibit the import and sale of connected vehicles equipped with certain hardware or software developed, manufactured, or supplied by Chinese or Russian-affiliated entities.
- Proposed rule would also prohibit the sale of connected vehicles manufactured by Chinese or Russian OEMs.
- Prohibitions would take effect between 2027 and 2030.
- If implemented, manufacturers
OFAC Issues New & Updated Russia-Related General Licenses in Connection with Recent Designations
On September 13, 2024, the United States designated and placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List three entities and two individuals for their connection to Russia’s destabilizing actions abroad, particularly efforts to undermine and manipulate the outcome of the October 2024 Moldovan presidential election.
OFAC Issues Final Rule on Procedures Related to Blocking Property
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a final rule on Updating Provisions Related to Blocking and Other Actions Related to Specific Property or Interests in Property. The rule is effective as of September 17, 2024.
The new rule aims to clarify OFAC’s process for issuing orders that block
Annual Blocked Property Reports Due to OFAC by September 30
All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions programs must file their Annual Report of Blocked Property (ARBP) by September 30, 2024.
This report is pursuant to 31 C.F.R. §§ 501.603
State Department Largely Adopts Proposed Rule Extending License Exemptions for Australia and the United Kingdom into an Interim Final Rule
On August 20, 2024, the State Department published an Interim Final Rule in the Federal Register amending the International Traffic in Arms Regulations (ITAR) to add a license exemption regime for exports, reexports, transfers, and temporary imports of defense articles and defense services to and between Australia and the United Kingdom. The Interim Final Rule
OFAC Publishes Interim Final Rule Extending Recordkeeping Requirement to 10 Years
On September 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Interim Final Rule to amend its Reporting, Procedures and Penalties Regulations under 31 C.F.R. Part 501, which extends recordkeeping requirements for certain transactions from 5 years to 10 years. This Interim Final Rule takes effect on March 12
Department of Labor Updates List of Goods Produced by Forced Labor
On September 5, 2024, the Department of Labor (DOL) released a revised version of its List of Goods Produced by Child Labor or Forced Labor. This 2024 report identifies the types of goods, the industries involved and the countries that the DOL has reason to believe are produced by child labor or forced labor
OFAC Issues Revised Russia Telecommunications General Licenses and an Alert on Russian Attempts to Evade Sanctions
On September 4, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia General License (GL) 25E that continues to authorize all transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation. This continues to allow for services incident to the exchange of