On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukrainian territory, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that added 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s continuing
OFAC Sanctions Facilitators of Iranian Oil Sales
On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in
OFAC Issues Updated Iran General License Covering Certain Services, Software and Hardware for Communications
On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on
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 OFAC sanctions programs must file their annual reports on such blocked property by September 30, 2022. This report is pursuant to 31 C.F.R. §§ 501.603. This report must include all blocked property held as
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Russian Oil
On September 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published preliminary guidance on how the United States, in coordination with the other G7 members, will implement a price cap on services related to the maritime transportation of Russian-origin crude oil and petroleum products. OFAC’s preliminary guidance reflects the joint
OFAC and BIS Implement Additional Sanctions Against Russia
On September 15, 2022, the Department of the Treasury and Department of Commerce took additional actions to sanction entities and individuals furthering Russia’s aggression against Ukraine and to tighten export controls targeting Russia’s military and defense capabilities.
OFAC Additions to the SDN List
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced
Treasury Issues Determinations on Quantum Computing Services in Russia
On September 15, 2022, the Department of the Treasury issued a Determination pursuant to E.O. 14071 that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of quantum computing services to any person located in the Russian Federation. This determination will take effect
OFAC Extends Authorizations Under Russia General License 13 for Payment of Various Fees
On September 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia-related General License (GL) 13B, “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 duties and purchase or receive permits,
Price Cap to Be Placed on Russian Oil in Response to Continued Aggression in Ukraine
In the latest effort to address Russia’s invasion of Ukraine, on September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to finalize and implement a price cap with respect to Russian-origin oil. As described, the plan would implement a comprehensive prohibition of services which enable maritime transportation of Russian-origin crude oil
BIS Issues FAQs to Address Evasion and Diversion Concerns
On August 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued several new Frequently Asked Questions (FAQ) addressing potential red flags for diversion concerns.
Regarding semiconductor foundries, one FAQ asks if there any special red flags that should be considered with regard to parties (e.g., integrated circuit designers) on the Entity