On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Russian Oil
On September 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published preliminary guidance on how the United States, in coordination with the other G7 members, will implement a price cap on services related to the maritime transportation of Russian-origin crude oil and petroleum products. OFAC’s preliminary guidance reflects the joint
OFAC and BIS Implement Additional Sanctions Against Russia
On September 15, 2022, the Department of the Treasury and Department of Commerce took additional actions to sanction entities and individuals furthering Russia’s aggression against Ukraine and to tighten export controls targeting Russia’s military and defense capabilities.
OFAC Additions to the SDN List
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced
Treasury Issues Determinations on Quantum Computing Services in Russia
On September 15, 2022, 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 quantum computing services to any person located in the Russian Federation. This determination will take effect
Plaintiffs in China Section 301 Tariff Refund Litigation File Comments on USTR’s Remand Explanation
On September 14, 2022, the plaintiff group in the ongoing China Section 301 tariff refund litigation before the Court of International Trade (CIT) filed its comments in response to the USTR’s remand explanation. The comments highlight that the CIT offered the USTR a final opportunity to explain its rationale and reasoning as to why it
OFAC Extends Authorizations Under Russia General License 13 for Payment of Various Fees
On September 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Russia-related General License (GL) 13B, “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 duties and purchase or receive permits,
Price Cap to Be Placed on Russian Oil in Response to Continued Aggression in Ukraine
In the latest effort to address Russia’s invasion of Ukraine, on September 2, 2022, the G7 Finance Ministers issued a statement confirming their intention to finalize and implement a price cap with respect to Russian-origin oil. As described, the plan would implement a comprehensive prohibition of services which enable maritime transportation of Russian-origin crude oil
USTR to Continue Section 301 Tariffs on China During Four-Year Review Process
On September 2, 2022, the Office of the United States Trade Representative (USTR) confirmed, as part of its statutory four-year review process under the Trade Act of 1974, that (1) domestic industry representatives benefiting from the tariff actions in the Section 301 investigation of China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property,
BIS Issues FAQs to Address Evasion and Diversion Concerns
On August 16, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued several new Frequently Asked Questions (FAQ) addressing potential red flags for diversion concerns.
Regarding semiconductor foundries, one FAQ asks if there any special red flags that should be considered with regard to parties (e.g., integrated circuit designers) on the Entity
Treasury Releases Annual CFIUS Report
On August 2, 2022, the Treasury Department, as the lead agency of the Committee on Foreign Investment in the United States (CFIUS), released a public version of its annual report to Congress regarding foreign direct investment in the United States. Assistant Secretary for Investment Security Paul Rosen stated, “This year’s Annual Report demonstrates that CFIUS