On October 27, 2023, the U.S. Department of Commerce announced an immediate pause on the issuance of new export licenses for certain firearms, related components and ammunition for a period of approximately 90 days. This pause applies globally to all non-governmental end users with some exceptions, notably for Ukraine, Israel and countries in Country Group
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.
U.S. Supreme Court Declines to Hear Section 232 Steel Appeal
On October 30, 2023, the U.S. Supreme Court declined to hear another Section 232 national security steel tariff appeal. On July 21, 2023, PrimeSource Building Products, Inc. filed Petition for a Writ of Certiorari with the U.S. Supreme Court, after the U.S. Court of Appeals for the Federal Circuit reversed the lower court decision of…
OFAC Again Extends Russia-Related General License No. 8 Regarding Transactions Related to Energy
On October 25, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued amended Russia-related General License No. 8H 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 related…
OFAC Loosens Venezuela Sanctions, Authorizes Transactions Involving Oil and Gas, State-Owned Gold Mining Company, and Certain Debt and Equity of Venezuela and PdVSA
- For a period of six months, OFAC permits a wide range of transactions tied to Venezuela’s oil and gas sector, including new investments and financial dealings with specific Venezuelan banks.
- OFAC allows all forms of transactions with Minerven, the Venezuelan state-owned gold mining company, nullifying prior sanctions solely in this sector.
- OFAC lifted
BIS Adds 13 Chinese Companies to Entity List for Involvement in Developing Advanced Computing Chips
On October 17, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding two Chinese entities and their subsidiaries (a total of 13 entities) to the Entity List due to their involvement in the development of advanced computing chips and having been found to be engaged in activities contrary…
OFAC Sanctions Entities for Violations of Russian Oil Price Cap and Issues Price Cap Coalition Advisory
On October 12, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two entities and identified as blocked property two vessels that used Price Cap Coalition service providers while carrying Russian crude oil above the Coalition-agreed price cap. See here for additional identifying information on these entities.
The United States is…
BIS Continues to Focus on and Sanction Entities Providing Support to Russia’s Military and Defense Industries
On October 6, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) added 49 entities from China, Estonia, Finland, Germany, India, Turkey, United Arab Emirates (UAE), and the United Kingdom to the Entity List after determining that these companies were “acting contrary to the national security or foreign policy interests of the United…
DHS Adds Three Xinjiang Entities to UFLPA List
On September 26, 2023, the Department of Homeland Security added three entities to the Uyghur Forced Labor Act (UFLPA) List as a result of each entity’s work with the government of the Xinjiang Uyghur Autonomous Region to recruit, transport, transfer, harbor or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups…
U.S., UK and EU Announce Updated List of Controlled “High-Priority” Items Restricted for Export to Russia
On September 19, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced additional items considered significant to Russian weaponry and are now restricted for export to both Russia and Belarus. In coordination with the United Kingdom and European Union, BIS continues to identify “high-priority items” by their six-digit Harmonized System (HS)…
OFAC Implements Additional Sanctions Targeting Russia’s Technology, Industrial, Construction and Financial Sectors
On September 14, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced another round of sanctions and economic restrictions targeting Russian elites and Russia’s industrial base, financial institutions, and technology suppliers. According to a press release, the sanctions on over 100 individuals and entities continues the effort “to leverage sanctions…
