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On June 25, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it would be delaying the effective date for certain filing requirements set forth in April 2020 regulations on military-related exports to China, Russia and Venezuela.  After significant pushback from industry representatives that more time was needed to transition to…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced that it has issued General License (“GL”) 37  (Authorizing the Wind Down of Transactions Involving Delos Voyager Shipping Ltd, Romina Maritime Co Inc, and Certain Vessels), which expires on July 21, 2020.   Additionally, OFAC issued frequently asked question (“FAQ”) 834 addressing the…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its revocation of general license 13E and issuance of general licenses 3H (“Authorizing Transactions Related to Dealings in Certain Bonds”) and 9G (“Authorizing Transactions Related to Dealings in Certain Securities”) to remove references to Nynas AB. Nynas is no longer being blocked…

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued two final rules and one proposed rule intended to prevent efforts by entities in China, Russia and Venezuela to acquire U.S. technology that could be used in development of weapons, military aircraft or surveillance technology through civilian supply chains or under civilian-use pretenses.…

Despite a tightening of economic sanctions on Venezuela under President Donald Trump, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) occasionally issues General Licenses clarifying, authorizing or exempting certain U.S. activities involving the Venezuelan government  or entities directly and indirectly affiliated with Petróleos de Venezuela, S.A (PdVSA).  Starting in January 2019, President…

In his State of the Union address to Congress last night, President Donald Trump spoke of the “great American comeback” and claimed that “[t]he years of economic decay are over.  The days of our country being used, taken advantage of, and even scorned by other nations are long behind us.” His prepared speech focused briefly…

The Department of Commerce’s Bureau of Industry and Security (BIS) further tightened U.S. sanctions on Cuba “for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Overall, the United States maintains a comprehensive embargo on trade with Cuba, and the export and reexport to Cuba of items subject to…

In September, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) continued to tighten its sanctions on Iran and Venezuela, and addressed a sanctions-evading scheme for Syria involving several Russian entities.

  • Iran: On September 20, 2019, OFAC announced that it was designating the Central Bank of Iran (CBI), the National Development

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