On April 29, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8I, once again extending the authorization to conduct transactions involving Vnesheconombank, Bank Financial Corporation Otkritie, Sovcombank, Sberbank, VTB Bank, Alfa-Bank, Rosbank, Bank Zenit, Bank Saint-Petersburg, and the Central Bank of Russia that are
Francesca M.S. Guerrero
Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.
BIS Revises Export Controls on Firearms Licensing Requirements
On April 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (IFR) updating the Export Administration Regulations (EAR) to enhance the control structure for firearms and related items under BIS’s jurisdiction. This IFR will be effective on May 30, 2024, and public comment will be accepted until…
President Biden Signs Law that Includes Provisions to Ban TikTok from the United States
On April 24, 2024, President Joseph Biden signed into law emergency supplemental appropriations (Pub. Law No. 118-50) that, among numerous measures, included the Protecting Americans from Foreign Adversary Controlled Applications Act. This now enacted law is most widely known for its efforts to ban Chinese-owned TikTok and comes after prior attempts to…
BIS Establishes New License Exception for Medical Devices Exported to Russia, Belarus and Occupied Areas of Ukraine
On April 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule introducing the new License Exception MED that enables delivery of humanitarian medical devices to the citizens of Russia, Belarus, and the Crimea region of Ukraine, and the occupied regions of Donetsk and Luhansk. This license exception is an effort…
BIS and OFAC Expand Export Controls and Sanctions on Iran for Aggression Toward Israel and Military Support for Russia
On April 18, 2024, the Departments of Commerce and the Treasury announced combined export control restrictions and economic sanctions against Iran for its attack on Israel on April 13, 2024. These actions are intended “to degrade and disrupt key aspects of Iran’s malign activity, including its UAV [Unmanned Aerial Vehicles] program and the revenue the…
OFAC Rescinds Authorization for Certain Oil and Gas Transactions Involving Venezuela and Issues Wind-Down License
On April 17, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 44A, “Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in Venezuela.” This license replaces General License (GL) 44 that was issued in October 2023 allowing for certain activities in this…
BIS Issues Interim Final Rule to Ease Export Controls on Australia and the United Kingdom
To “further enhance defense industrial base cooperation and technology innovation with Australia and the United Kingdom,” the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) on April 18, 2024 to ease various licensing requirements prescribed by the Export Administration Regulations (“EAR”) for exports, reexports, or transfers (in-country) to…
CFIUS Proposed Rulemaking Seeks to Refine and Expand Enforcement and Penalty Regulations
On April 15, 2024, the U.S. Department of the Treasury, as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPR) to enhance certain CFIUS procedures. This proposed rule would modify certain provisions in the CFIUS regulations pertaining to: (i) penalties for violations of statutory or…
OFAC Again Extends Authorizations Under Russia General License 13
On April 12, 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 13I, “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…
United States Bans Imports of and Services Related to Russian-Origin Aluminum, Copper and Nickel
On April 12, 2024, the Office of Foreign Assets Control (OFAC) signed a new determination under section 1(a)(i)(A) of Executive Order 14068 of March 11, 2022 as amended by Executive Order 14114 of December 22, 2023. According to this determination, the importation and entry into the United States, including importation for admission into a foreign…
