On February 20, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended Russia-related General License (GL) 83 by issuing a revised version: GL 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.” The modified GL 83A maintains the
Treasury Releases Semi-Annual List of Countries Requiring Cooperation With International Boycotts
In addition to its role in enforcing U.S. export control laws, the Department of Commerce’s Bureau of Industry and Security (BIS) is charged with administering and enforcing the antiboycott laws under the Export Administration Act. These antiboycott laws were adopted to encourage and, in some circumstances, require U.S. companies to refuse to participate in foreign
White House Releases Updated Critical and Emerging Technologies List
The Executive Office of the President, via the National Science and Technology Council, has released an updated list of critical and emerging technologies that are potentially significant to U.S. national security. This list updates and revises the critical technologies list identified in the October 2020 report, “National Strategy for Critical and Emerging Technologies” and an
OFAC Issues Determinations to Prohibit Import of Russian-Origin Diamonds
On December 22, 2023, President Joseph Biden amended Executive Order (EO) 14068 by additionally authorizing the prohibition on the importation and entry into the United States of diamonds of Russian Federation origin. See Thompson Hine Update of January 2, 2024. The EO required that such a ban be implemented only after the issuance of
OFAC Issues Oil Price Cap Compliance and Enforcement Alert Recommending Methods to Mitigate Evasion Risks
On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the
United States to Reinstate Certain Sanctions on Venezuela
On January 30, 2024, the Department of State announced in a press release that the United States would be reinstating certain sanctions actions on Venezuela in light of recent activities by President Nicolás Maduro and his regime, including the recent barring of opposition candidates from competing in Venezuela’s 2024 presidential election.
In October 2023, the
BIS Issues Policy Memo on the Voluntary Self-Disclosure Process
- The policy memorandum builds upon two previous updates to the VSD process announced in June 2022 and April 2023. It gives direction to companies wishing to take advantage of certain faster processing options for VSDs.
- Cuts some requirements for submissions of minor or technical infractions of U.S. export controls to reduce the administrative
USTR Releases Supplemental Multiagency Business Advisory on Burma
On January 26, 2024, the Office of the U.S. Trade Representative (USTR) released a Supplemental Business Advisory highlighting continued risks and exposure of doing business in Burma. In January 2022, the U.S. Departments of State, the Treasury, Commerce, Homeland Security, Labor and the USTR first published a business advisory on heightened risk of doing business
BIS Implements Additional Sanctions Against Russia and Belarus
Effective January 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded export controls and sanctions against Russia for its continuing aggression against Ukraine and Belarus for its complicity in such activities. In a Final Rule, BIS is expanding the scope of the Export Administration Regulations’ (EAR) Russian and Belarusian
U.S. Re-Designates Ansarallah (aka the Houthis) as a Global Terrorist Group
On January 17, 2024, the Department of State announced that it was re-designating Yemen-based Ansarallah, commonly referred to as the Houthis, as a Specially Designated Global Terrorist (SDGT) group. This designation will be effective as of February 16, 2024, when Ansarallah will be placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC)