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 June 1, 2022, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a Final Rule amending the Export Administration Regulations (EAR) to adopt a congressional notification requirement for license applications of semiautomatic firearms meeting certain requirements.  This final rule is effective on July 18, 2022.

This Final Rule adds a new section

The Office of the U.S. Trade Representative (USTR) has announced that it will again extend Section 301 product exclusions for imports from China of medical care products needed to address the COVID-19 pandemic. The USTR will extend product exclusions on 81 medical care products, as set forth in Annex B of USTR’s announcement, for an

On May 27, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 8J, extending authorization until December 1 for certain activities previously authorized under General License 8I. General License 8J authorizes the continuation of transactions and activities “ordinarily incident and necessary to the limited maintenance of essential

On May 23, 2022, the U.S. Departments of State, the Treasury, Commerce, and Labor issued a joint advisory for U.S. businesses operating in Sudan. The advisory highlights the risks associated with conducting business with Sudan’s state-owned enterprises (“SOEs”), which are effectively controlled by the Sudanese military since its seizure of power on October 25, 2021.

On May 23, 2022, the United States and several allies in the Asia-Pacific-India region announced the launch of the Indo-Pacific Economic Framework for Prosperity (IPEF) to pursue regional economic engagement. Secretary of Commerce Gina Raimondo stated, “This framework will enable the United States to expand its economic leadership in the Indo-Pacific and work with our

On May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 22, which authorizes certain transactions, including processing or transfer of funds on behalf of third-country entities, otherwise prohibited under the Syrian Sanctions Regulations (SSR) that are ordinarily incident and necessary to activities in the

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued several Russia-related general licenses under the Russian Harmful Foreign Activities Sanctions Regulations, 31 C.F.R. Part 587 (RuHSR). These licenses authorize certain activities which would otherwise be prohibited under OFAC sanctions toward Russia:

GL 26A extends until July 12, 2022 existing authorizations for

Key Notes:

  • Persons, including non-U.S. persons, providing accounting, trust and corporate formation, and management consulting services in Russia may be added to the SDN List.
  • U.S. persons are prohibited from providing these same services to Russian persons unless the recipient of the services is the subsidiary of a U.S. person.

The Department of the Treasury’s

On May 8, 2022, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented additional sanctions on several sectors of the Russian economy.  OFAC designated three Russian telecommunications companies and placed them on the Specially Designated Nationals (SDN) list, noting that they are Russian state-controlled television stations generating revenue for the Russian government.