On May 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State announced further sanctions targeting Russia’s military-industrial base and chemical and biological weapons programs as well as companies and individuals in third countries that continue to help Russia acquire key inputs for weapons or defense-related production.
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
New Legislation Extends U.S. Sanctions Enforcement Period to Ten Years
On April 24, 2024, President Biden signed into law a significant amendment to the statute of limitations for violations under U.S. sanctions laws, as part of the national security package (H.R. 815). This change extends the period for enforcement actions from five to ten years, reflecting a more robust approach to national security…
OFAC Again Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On April 29, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8I, once again 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…
BIS Revises Export Controls on Firearms Licensing Requirements
On April 30, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (IFR) updating the Export Administration Regulations (EAR) to enhance the control structure for firearms and related items under BIS’s jurisdiction. This IFR will be effective on May 30, 2024, and public comment will be accepted until…
President Biden Signs Law that Includes Provisions to Ban TikTok from the United States
On April 24, 2024, President Joseph Biden signed into law emergency supplemental appropriations (Pub. Law No. 118-50) that, among numerous measures, included the Protecting Americans from Foreign Adversary Controlled Applications Act. This now enacted law is most widely known for its efforts to ban Chinese-owned TikTok and comes after prior attempts to…
BIS Establishes New License Exception for Medical Devices Exported to Russia, Belarus and Occupied Areas of Ukraine
On April 26, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) published a final rule introducing the new License Exception MED that enables delivery of humanitarian medical devices to the citizens of Russia, Belarus, and the Crimea region of Ukraine, and the occupied regions of Donetsk and Luhansk. This license exception is an effort…
BIS and OFAC Expand Export Controls and Sanctions on Iran for Aggression Toward Israel and Military Support for Russia
On April 18, 2024, the Departments of Commerce and the Treasury announced combined export control restrictions and economic sanctions against Iran for its attack on Israel on April 13, 2024. These actions are intended “to degrade and disrupt key aspects of Iran’s malign activity, including its UAV [Unmanned Aerial Vehicles] program and the revenue the…
OFAC Rescinds Authorization for Certain Oil and Gas Transactions Involving Venezuela and Issues Wind-Down License
On April 17, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 44A, “Authorizing the Wind Down of Transactions Related to Oil or Gas Sector Operations in Venezuela.” This license replaces General License (GL) 44 that was issued in October 2023 allowing for certain activities in this…
BIS Issues Interim Final Rule to Ease Export Controls on Australia and the United Kingdom
To “further enhance defense industrial base cooperation and technology innovation with Australia and the United Kingdom,” the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued an interim final rule (“IFR”) on April 18, 2024 to ease various licensing requirements prescribed by the Export Administration Regulations (“EAR”) for exports, reexports, or transfers (in-country) to…
USTR Initiates Section 301 Investigation Targeting China’s Maritime, Logistics and Shipbuilding Sectors
Note: For more information on this topic, please see our client update of April 23rd.
On April 17, 2024, the Office of the U.S. Trade Representative (USTR) initiated an investigation targeting the acts, policies, and practices of the maritime, logistics and shipbuilding sectors of the People’s Republic of China (PRC). This action results from a…
