On October 7, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule adding 31 Chinese entities to its Unverified List on the basis that it has been “unable to verify their bona fides because an end-use check could not be completed satisfactorily for reasons outside the U.S. Government’s control.”
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 Expands Russia Sanctions Following Putin’s Illegal Annexation of Four Ukrainian Regions
On September 30, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated hundreds of Russian individuals and entities and placed them on the Specially Designated Nationals (SDN) List in response to Russia’s illegal annexation of additional Ukrainian territories.
The new designations target 14 suppliers connected to the country’s military-industrial complex, including…
Commerce Adds Numerous Russian Entities to BIS’ Entity List
On September 30, 2022, in response to Russia President Vladimir Putin’s illegal effort to annex further Ukrainian territory, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule that added 57 entities located in Russia and the Crimea region of Ukraine to the Entity List for supporting the Russian military’s continuing…
OFAC Sanctions Facilitators of Iranian Oil Sales
On September 29, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a network of international companies for facilitating the sale of hundreds of millions of dollars’ worth of Iranian petrochemicals and petroleum products to South and East Asia. OFAC targeted the network, which includes a myriad of front companies in…
OFAC Issues Updated Iran General License Covering Certain Services, Software and Hardware for Communications
On September 23, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a revised Iran General License (GL) D-2 which authorizes the export, reexport by U.S. persons to Iran of certain services, software and hardware incident to communication. The purpose of the revised GL is to bring this OFAC guidance on…
Commerce Section 232 Magnet Import Investigation Concludes Without Tariffs
On September 21, 2022, after a year-long Section 232 investigation, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that rare earth neodymium-iron-boron (NdFeB) magnet imports threaten national security. The investigation was initiated in September 2021 due to concerns that “critical national security systems rely on NdFeB permanent magnets, including fighter aircraft and…
Annual Blocked Property Reports Due to OFAC by September 30
All U.S. persons and persons otherwise subject to U.S. jurisdiction, not only U.S. financial institutions, holding property blocked pursuant to various OFAC sanctions programs must file their annual reports on such blocked property by September 30, 2022. This report is pursuant to 31 C.F.R. §§ 501.603. This report must include all blocked property held as…
OFAC Publishes Preliminary Guidance on Price Cap to Be Placed on Russian Oil
On September 9, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published preliminary guidance on how the United States, in coordination with the other G7 members, will implement a price cap on services related to the maritime transportation of Russian-origin crude oil and petroleum products. OFAC’s preliminary guidance reflects the joint…
OFAC and BIS Implement Additional Sanctions Against Russia
On September 15, 2022, the Department of the Treasury and Department of Commerce took additional actions to sanction entities and individuals furthering Russia’s aggression against Ukraine and to tighten export controls targeting Russia’s military and defense capabilities.
OFAC Additions to the SDN List
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced…
Treasury Issues Determinations on Quantum Computing Services in Russia
On September 15, 2022, 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 quantum computing services to any person located in the Russian Federation. This determination will take effect…
