On July 21, 2023, PrimeSource Building Products, Inc. filed a Petition for a Writ of Certiorari with the U.S. Supreme Court, after unsuccessfully seeking an en banc hearing before all of the judges at the U.S. Court of Appeals for the Federal Circuit. In that decision, a three-judge panel reversed a lower court decision and
BIS Issues Policy Memo to Strengthen Antiboycott Reporting and Compliance
- The Boycott Reporting Form has been amended to
OFAC Designates Additional Russian Companies, Banks and Vessels to Further Hinder Russia’s Military Efforts in Ukraine
On July 20, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented further sanctions against Russia to restrict “access to products that support its military and war efforts; reduce Russia’s revenue from the metals and mining sector; undermine its future energy capabilities; degrade Russia’s access to the international financial system; and
OFAC Again Revises Venezuela General License, Extending Delay of PdVSA 2020 8.5% Bond-Related Authorizations
On April 19, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 5L, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After October 20, 2023,” which continues to delay U.S. persons’ ability to enforce bondholder rights to the CITGO
OFAC Issues General License 40B Continuing to Authorize Certain Transactions Involving the Export of LP Gas to Venezuela
On July 10, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 40B, “Authorizing Certain Transactions Involving the Exportation or Reexportation of Liquefied Petroleum Gas to Venezuela.” This revised general license continues authorization of all transactions and activities related to the exportation or reexportation, directly or indirectly
Five Eyes Partners Formalize Cooperation on Export Control Enforcement Efforts
On June 28, 2023, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that the United States was joining its “Five Eye” partners – Australia, Canada, New Zealand, and the United Kingdom – in committing to formally coordinate on export control enforcement. While these allied countries have shared intelligence and other national security
FinCEN & BIS Issue Joint Alert Encouraging Continued Vigilance Regarding Potential Russia Export Control Evasion
- The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
- The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
- Included is a list of certain “high priority” items organized according to their Harmonized
OFAC Issues New General Licenses Under Sudan-Related Sanctions
- General License No. 1 authorizes transactions for the conduct of the official business
Treasury Issues Determinations on Prohibitions Related to Architecture, Engineering, Construction, Manufacturing, and Transportation Sectors in Russia
On May 19, 2023, 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 architecture or engineering services to any person located in the Russian Federation. The determination excludes the
OFAC Again Extends Venezuela General License for Limited Maintenance or Wind-Down of Transactions Involving PdVSA and Certain Entities
On May 23, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8L, extending authorization until November 19, 2023 for certain activities previously authorized under General License 8K. General License 8L authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of