On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8O︎, extending authorization until May 9, 2025 for certain activities previously authorized under General License 8N. General License 8O︎ authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential
OFAC Again Extends Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On November 7, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5Q, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After March 7, 2025,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
Commerce, State and Treasury Implement Further Sanctions on Russian and Third-Country Individuals and Entities that Continue to Support Russia’s War Efforts in Ukraine
On October 30, 2024, the Departments of the Treasury, State and Commerce undertook further sanctions against “enablers of Russia’s military-industrial base.” In total, the actions taken by the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) sanction over 300 individuals and entities involved in supplying Russia with advanced technology
CFIUS Issues Final Rule Expanding Coverage of Real Estate Transactions Near More Than 60 Military Installations
On November 7, 2024, the Committee on Foreign Investment in the United States (CFIUS), in coordination with the Department of Defense (DoD), issued a Final Rule that expanded its ability to review certain real estate transactions by foreign persons near more than 60 military bases and installations across 30 states. In addition, CFIUS’s jurisdiction over
DHS Updates UFLPA Entity List with Additional Chinese Textile Companies
On October 31, 2024, the Department of Homeland Security (DHS) announced that effective November 1, 2024, four textile Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be facilities and entities that source material from the Xinjiang Uyghur Autonomous Region or from persons working with the
BIS, DDTC Publish a Series of Rules to Modernize U.S. Space-Related Export Controls
On October 17, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to reduce controls on a variety of less sensitive space-related items, thereby ensuring the U.S. space industrial base remains globally competitive while also bolstering the U.S. international space partnerships. Concurrently
BIS Adds 26 Companies to the Entity List
On October 21, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 26 companies to its Entity List for activities contrary to U.S. national security and foreign policy for alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls
USTR Opens Section 301 Tariff Exclusion Process for Certain Machinery from China Used in Domestic Manufacturing
On October 15, 2024, the Office of the United States Trade Representative (USTR) announced that it has opened a process for interested parties to request that certain machinery from China be temporarily excluded from Section 301 duties in the “Investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation”. Upon
OFAC Expands Sanctions on Iran for Missile Attack on Israel
On October 11, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it was expanding sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel. The Secretary of the Treasury has identified the petroleum and petrochemical sectors of the Iranian economy pursuant to a
BIS Enhances Its Enforcement Discretion: Final Rule Revamps Voluntary Self-Disclosure Process, Abolishes Penalty Caps and Amends Penalty Guidelines
- The final rule took effect September 16. It codifies the series of “policy memoranda” BIS began issuing in 2022 to clarify the agency’s evolving attitude toward voluntary self-disclosures, which in turn aimed to encourage companies, universities and individuals to engage in the process after believing a violation of the Export Administration Regulations, or