On April 15, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5O, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After August 13, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
BIS Releases Interim Final Rule Further Revising Export Controls on Advanced Computing and Semiconductor Manufacturing
On April 4, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) released another Interim Final Rule (IFR) offering clarification and correcting inadvertent errors made in earlier rulemakings regarding the implementation of significant export controls on certain advanced computing items and supercomputer and semiconductor end use. This latest rule is effective April 4
Commerce Releases New Resource to Help Identify Boycott-Related Requests
On March 28, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a new resource to help identify boycott-related requests U.S. persons and companies may receive during the regular course of conducting business. The resource is a public list of entities identified as making a boycott-related request in reports received by the BIS
BIS Amends EAR to Expand Export Controls on OFAC SDN-Listed Persons
On March 20, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule implementing restrictions under the Export Administration Regulations (EAR) on persons who have been designated and placed on the Specially Designated Nationals (SDN) List maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). Under Secretary
New Law Adds the Secretary of Agriculture to the Committee on Foreign Investment in the United States
On Saturday, March 9, 2024, President Biden signed a six-bill appropriations package to fund the U.S. government through September 30, 2024. In doing so, he codified a notable trade-related policy rider that adds the Secretary of Agriculture “on a case by case basis” to the Committee on Foreign Investment in the United States (“CFIUS” or
U.S. Sanctions Hundreds of Entities to Mark the Second Anniversary of Russia’s Invasion of Ukraine
- 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