On May 19, 2023, 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 architecture or engineering services to any person located in the Russian Federation. The determination excludes the

Samir D. Varma
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 23, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8L, extending authorization until November 19, 2023 for certain activities previously authorized under General License 8K. General License 8L authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of…
OFAC and State Department Designate and Sanction Over 225 Individuals and Entities Involved in Russia’s War Against Ukraine
On May 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned and placed on the Specially Designated Nationals (SDN) List over 225 individuals, entities, vessels and aircraft. These actions came at the same time the G7 member countries were meeting and jointly announced both continued…
BIS Issues Final Rules Implementing Additional Sanctions Against Russia and Belarus and Adding Entities to the Entity List
On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a significant Final Rule implementing additional sanctions and revising existing export controls against Russia and Belarus for ongoing aggression against Ukraine. According to the announcement, these revisions and additions seek to better align U.S. sanctions with the controls that have…
USTR Again Extends Section 301 Tariff Exclusions for Chinese COVID-19 Medical Products
The Office of the U.S. Trade Representative (USTR) has issued a Notice announcing the continuing extension of Section 301 tariff exclusions for 81 medical products that were scheduled to expire on May 15, 2023. These extensions come after a 75-day extension in February 2023 when USTR sought public comment on whether further exclusions were necessary…
Plaintiffs File Notice of Appeal in China Section 301 Tariff Refund Litigation
On May 12, 2023, the plaintiff group in the China Section 301 tariff refund litigation, in response to the recently issued decision by the U.S. Court of International Trade (CIT) upholding those Section 301 tariffs, formally filed its Notice of Appeal. The appeal will be heard by the U.S. Court of Appeals for the…
OFAC Again Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On May 5, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8G 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 related to energy…
CFIUS Seeks to Expand List of Covered Military Institutions to Include Locations in Additional States
On May 5, 2023, the Department of the Treasury’s Office of Investment Security published in the Federal Register a Proposed Rule that would amend the regulations pertaining to certain transactions by foreign persons involving real estate in the United States pursuant to section 721 of the Defense Production Act of 1950, as amended, and implemented…
President Biden Introduces New Sudan-Related Sanctions
On May 4, 2023, President Biden signed a new Executive Order, Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition, stating that the violence taking place in Sudan “is a tragedy” and “must end.”
Finding that the situation in Sudan constitutes an extraordinary threat to U.S. national security…
Deputies of the G7 Enforcement Coordination Mechanism Discuss Russia Sanctions Evasion
On April 27, 2023, deputies of the Group of Seven (G7) Enforcement Coordination Mechanism met to discuss the need to increase enforcement of multilateral sanctions and export controls implemented since Russia’s invasion of Ukraine in February 2022 in order to deny Russia access to the materials it requires to equip its military and the revenue…