On August 15, 2024, the Department of State’s Directorate of Defense Trade Controls (DDTC) published a final rule adding two activities to the definition of “activities that are not exports, reexports, retransfers, or temporary imports” in § 120.54 of the International Traffic in Arms Regulations (ITAR). The final rule, which goes into effect September 16
OFAC Implements Further Sanctions on Belarus
On August 9, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 19 individuals and 14 entities for their continued support of “Russia’s war in Ukraine through military resource production and transshipment of goods to Russia, sanctions evasion on behalf of Belarusian defense entities, and revenue generation for Belarusian oligarchs in
OFAC Issues Another Extension of Venezuela General License Delaying PdVSA 2020 8.5% Bond-Related Authorizations
On August 12, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5P, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After November 12, 2024,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
DHS Updates UFLPA Entity List with Five Chinese Entities
On August 8, 2024, the Department of Homeland Security (DHS) announced via a Federal Register notice that effective immediately, five Chinese entities have been added to the UFLPA Entity List. These entities have been determined by DHS to be either: (i) working with the government of the Xinjiang Uyghur Autonomous Region (XUAR) to recruit
OFAC Extends Wind Down Authorization for Transactions with Certain Russian Financial Exchanges
On August 2, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two revised general licenses regarding conducting financial transactions involving: (i) the Moscow Exchange (MOEX), Russia’s largest public trading markets for equity, fixed income, derivative, foreign exchange, and money market products, as well as Russia’s central securities depository and the
Commerce and State Departments Issue Proposed Rules Addressing Restrictions on U.S. Persons’ Support for Foreign Military, Intelligence, and Security Services and Controls to Protect National Security and Human Rights
On July 29, 2024, both the Departments of Commerce and State issued separate but complementary proposed rules seeking public comment on enhanced restrictions on exports, reexports, or support to military or intelligence end users and end uses in countries of concern, consistent with the Fiscal Year 2023 National Defense Authorization Act (NDAA). The Department of Commerce’s
Treasury Releases Annual CFIUS Report
On July 23, 2024, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its 2023 Annual Report to Congress regarding foreign direct investment in the United States. The report highlights key indicators of the CFIUS process and provides statistics on transactions
Regulations Issued to Redesignate BIS as the Authority Administering Rules for Information and Communications Technology and Services Tied to Foreign Adversaries
The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Final Rule that redesignates regulations governing the procedures for the review of certain transactions involving information and communications technology and services (ICTS) designed, developed, manufactured, or supplied by persons owned by, controlled by, or subject to the jurisdiction or direction of a
OFAC Continues to Extend Authorizations Under Russia General License 13
On July 10, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13J, “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
CFIUS Issues Proposed Rule to Expand Coverage of Real Estate Transactions Near Military Installations
On July 8, 2024, the Department of the Treasury’s Office of Investment Security issued a Notice of Proposed Rulemaking seeking to add 59 military installations, across 30 states, to the list of installations around which the Committee on Foreign Investment in the United States (CFIUS) has jurisdiction regarding certain real estate transactions involving foreign persons.