On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the
U.S. Announces New Sanctions to Promote Peace, Security, and Stability in the West Bank
On February 1, 2024, the United States introduced new sanctions to promote peace in the West Bank, targeting recent actions that jeopardize the region’s stability, including attacks by Israeli settlers against Palestinians and Palestinian attacks against Israelis. This follows the related visa restriction policy announced by the State Department on December 5, 2023.
The sanctions have
United States to Reinstate Certain Sanctions on Venezuela
On January 30, 2024, the Department of State announced in a press release that the United States would be reinstating certain sanctions actions on Venezuela in light of recent activities by President Nicolás Maduro and his regime, including the recent barring of opposition candidates from competing in Venezuela’s 2024 presidential election.
In October 2023, the
How Misaligned Commitments on Social Issues Create Risks for Your Company
The “S” in “ESG” (environmental, social, and governance) includes an extensive list of factors like workplace culture; environmental justice; health and safety; policies on diversity, equity, and inclusion; labor standards; data privacy; human rights; racial justice; and product safety. In the past several years, consumers and shareholders have become increasingly focused on company performance in
BIS Issues Policy Memo on the Voluntary Self-Disclosure Process
- The policy memorandum builds upon two previous updates to the VSD process announced in June 2022 and April 2023. It gives direction to companies wishing to take advantage of certain faster processing options for VSDs.
- Cuts some requirements for submissions of minor or technical infractions of U.S. export controls to reduce the administrative
USTR Releases Supplemental Multiagency Business Advisory on Burma
On January 26, 2024, the Office of the U.S. Trade Representative (USTR) released a Supplemental Business Advisory highlighting continued risks and exposure of doing business in Burma. In January 2022, the U.S. Departments of State, the Treasury, Commerce, Homeland Security, Labor and the USTR first published a business advisory on heightened risk of doing business
BIS Implements Additional Sanctions Against Russia and Belarus
Effective January 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) again expanded export controls and sanctions against Russia for its continuing aggression against Ukraine and Belarus for its complicity in such activities. In a Final Rule, BIS is expanding the scope of the Export Administration Regulations’ (EAR) Russian and Belarusian
U.S. Re-Designates Ansarallah (aka the Houthis) as a Global Terrorist Group
On January 17, 2024, the Department of State announced that it was re-designating Yemen-based Ansarallah, commonly referred to as the Houthis, as a Specially Designated Global Terrorist (SDGT) group. This designation will be effective as of February 16, 2024, when Ansarallah will be placed on the Department of the Treasury’s Office of Foreign Assets Control (OFAC)
OFAC Again Extends Authorizations Under Russia General License 13
On January 18, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13H, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import
Annual and Semi-Annual Encryption Reports Due to BIS by February 1, 2024
As a reminder to our readers, the annual encryption self-classification report and semi-annual sales report for certain encryption items are due to be filed by February 1, 2024.
Annual Self-Classification Report
The self-classification report covers less sensitive items described under the Department of Commerce’s Bureau of Industry and Security (BIS) License Exception ENC (b)(1) (i.e.,