Photo of 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.

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two Russia-related General Licenses (GL) authorizing certain limited activities with Russian financial institutions which have been blocked and designated on the Specially Designated Nationals (SDN) List.

Placement on the SDN List results in all property and interests in property

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

On August 17, 2022, the Office the U.S. Trade Representative announced that formal negotiations have commenced with Taiwan on the United States-Taiwan Initiative on 21st Century Trade. This trade initiative was first announced in June 2022 as an effort to “deepen the economic and trade relationship, advance mutual trade priorities based on shared values, and

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

On August 2, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) added further Russian individuals, entities and vessels to its Specially Designated Nationals (SDN) List.  The designations include numerous Russian individuals connected to Russia President Vladimir Putin, as well as multinational companies Investitsionnaya Kompaniya MMK-FINANS (an investment and financial copany) and

On August 1, 2022, and as directed by the U.S. Court of International Trade (CIT) in its April 2022 decision (see Update of April 6, 2022), the Office of the U.S. Trade Representative (USTR) filed a 90-page explanation in support of its rationale for imposing List 3 and List 4A tariff determinations to

Both the Senate and House this week passed the Chips Act of 2022 (H.R. 4346) by comfortable bipartisan margins, sending it to the desk of President Joseph Biden for signature and enactment. The Act seeks to address that fact that only about 12% of semiconductor chips are currently manufactured in the United States and provides

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 44 authorizing transactions ordinarily incident and necessary to the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of tax preparation or filing services to any

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) issued General License (GL) 30A authorizing transactions through December 16, 2022 involving SEFE Securing Energy for Europe GmbH (formerly known as Gazprom Germania GmbH) or any entity in which SEFE Securing Energy for Europe GmbH owns, directly or indirectly, a 50

On July 14, 2022, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released a food security fact sheet on Russian sanctions and agricultural trade and an amended General License (GL) 6B to broaden the scope of the authorizations relating to transactions involving agricultural and medical products. The Department’s press release emphasized that “[a]gricultural