On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 30A authorizing transactions through December 16, 2022 involving SEFE Securing Energy for Europe GmbH (formerly known as Gazprom Germania GmbH) or any entity in which SEFE Securing Energy for Europe GmbH owns, directly or indirectly, a 50
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.
Department of Treasury Releases Amended General License 6B and a New Fact Sheet on Agricultural Trade with Russia
On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released a food security fact sheet on Russian sanctions and agricultural trade and an amended General License (GL) 6B to broaden the scope of the authorizations relating to transactions involving agricultural and medical products. The Department’s press release emphasized that “[a]gricultural…
OFAC Sanctions Additional Russian Entities and Persons
On June 28, 2022, The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 70 entities and 29 individuals involved in Russia’s defense industrial base. In addition, the Department of State impose visa restrictions on 511 Russian military officers, and sanctioned an additional 45 entities and 29 individuals. The designations and placement of…
U.S. Bans Gold Imports of Russian Origin
On June 28, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), in consultation with the Departments of Commerce and State, issued a determination prohibiting gold imports from Russia, the country’s largest non-energy export, effective immediately. According to the determination, gold imports of Russian Federation origin are prohibited, except to the extent…
U.S. and G7 Leaders Commit to Address China’s Unfair Trade Practices
During meetings among the G7 leaders on June 28, 2022, President Joseph Biden and the other G7 leaders committed to a “unified approach to confront” China’s trade-distorting industrial directives. According to a White House Fact Sheet, such actions will include:
- sharing insights and best practices to identify, monitor and minimize vulnerabilities and logistic bottlenecks
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U.S. to Increase Tariffs on Imports of Russian Goods; G7 Leaders Commit to Further Sanctions Against Russia
On June 27, 2022, President Joseph Biden issued a Presidential Proclamation announcing that the United States was increasing the duty rate to 35% ad valorem on certain products from Russia effective July 28, 2022. The White House indicated that this higher tariff will affect “more than 570 groups of Russian products worth approximately $2.3 billion”;…
BIS Adds 71 Russian and Belarusian Companies to Entity List
On June 2, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 71 entities located in Russia and Belarus to the Entity List in further response to Russia’s invasion of Ukraine. These entities have been determined by the U.S. government to be acting contrary to the national security…
OFAC Designates Additional Russian Entities and Persons and Issues Russia-Related General Licenses
On June 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated and blocked numerous additional Russian and related entities that are “key networks” relied upon by President Vladimir Putin and other Russian elites “to attempt to hide and move money and anonymously make use of luxury assets around the globe.”…
BIS Issues Rule for Congressional Notification of Exports of Certain Semiautomatic Firearms
On June 1, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule amending the Export Administration Regulations (EAR) to adopt a congressional notification requirement for license applications of semiautomatic firearms meeting certain requirements. This final rule is effective on July 18, 2022.
This Final Rule adds a new section…
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 27, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8J, extending authorization until December 1 for certain activities previously authorized under General License 8I. General License 8J authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential…
