On November 14, 2023, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an important guidance document to ensure the provision of humanitarian aid to the Palestinian people in Gaza, while also maintaining strict controls to prevent funds from reaching Hamas. OFAC clarified that “U.S. sanctions do not stand in the
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.
OFAC, State and BIS Announce Further Sanctions on Companies Supporting Russia’s War Efforts
On November 2, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), the Department of State, and the Department of Commerce’s Bureau of Industry and Security (BIS) announced a combined effort to designate and sanction numerous additional Russian individuals and entities who have been determined to be assisting in the war against…
Commerce Issues Further Export Controls Targeting China’s Semiconductor Manufacturing and Advanced Computing Capabilities
- These two Interim Final Rules reinforce the October 7, 2022, controls appended to the EAR to restrict China’s ability to both purchase and manufacture certain high-end chips critical for military advantage.
- The rules impose controls on additional types of semiconductor manufacturing equipment, adjust the parameters that determine whether an advanced computing chip is
BIS Halts New Licenses for Firearm Exports
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…
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…
