On February 10, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 23 that authorizes until August 8, 2023 all transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations under 31 C.F.R. Part 542. The GL makes clear
Treasury Publishes Final Guidance on the Russian Oil Price Cap
On February 3, 2023, the Department of the Treasury (Treasury) issued multiple determinations related to the price cap to be set on Russian-origin petroleum products. Treasury also published finalized guidance on the broader price cap policy implemented by the “Price Cap Coalition” – an international coalition that includes the United States, the G7, the European Union
GAO Report Notes Supply Chain Resilience with Trade Partners Requires Expanded Diplomatic Engagement
In February 2021 and pursuant to Executive Order 14017, “America’s Supply Chains,” President Joe Biden directed a review across all federal agencies to address vulnerabilities in the supply chains for critical goods. See Update of February 25, 2021. Subsequent federal agency reviews and a White House report found five key U.S. supply chain vulnerabilities
CBP Removes Forced Labor Finding Pertaining to Palm Oil and Derivatives Produced by Malaysia’s Sime Darby Plantation
On February 3, 2023, U.S. Customs and Border Patrol (CBP) issued a determination in the Federal Register providing notice that it has determined that palm oil and various derivatives thereof “are no longer being mined, produced, or manufactured wholly or in part with the use of convict, forced, or indentured labor by the Sime Darby
U.S. Hosts Initial Ministerial of the Americas Partnership for Economic Prosperity
On January 27, 2023, U.S. Secretary of State Antony Blinken and U.S. Trade Representative Katherine Tai hosted the initial ministerial for the Americas Partnership for Economic Prosperity (APEP), a regional framework for cooperation to promote inclusive economic growth and strengthen competitiveness. The APEP consists of the United States, Barbados, Canada, Chile, Colombia, Costa Rica, the
BIS Includes Macau Under Semiconductor Export Controls Implemented Against China
On January 18, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an Interim Final Rule extending export controls currently in place for China on advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items to the Macau Special Administrative Region of China (“Macau”). While China
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2023
As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2023.
Annual Self-Classification Report
The self-classification report covers less sensitive items covered under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.
OFAC Again Revises Venezuela General License Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations
On January 7, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5J, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After April 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
OFAC Amends Several Russia-Related General Licenses
- Russia-related General License 6C, “Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Petroleum Products of Russian Origin
On December 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published preliminary guidance on how the United States will implement a price cap policy on petroleum products of Russian origin. OFAC notes that with this preliminary guidance the agency will likely “take a similar approach for Russian petroleum products as