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U.S. State Department reinstates Cuba Restricted List

The U.S. Department of State has formally republished the Cuba Restricted List, restoring prohibitions on direct financial transactions with numerous Cuban military, intelligence, and security-linked entities. This move...more

OFAC takes the position that certain kinds of SDN participation in public conferences is not a prohibited service under U.S....

The U.S. Department of Treasury’s Office of Foreign Assets Control issued a formal guidance letter stating that certain kinds of Specially Designated Nationals could speak at a public conference to share their individual...more

U.S. Department of Commerce expands controls on advanced semiconductors and establishes new controls on closed AI model weights

The new interim final rule imposes new global licensing requirements for ECCNs 3A090.a, 4A090.a, and corresponding .z items; controls for closed AI model weights; updated data center validated end-user authorizations;...more

The United States and the United Kingdom impose new sanctions against the Russian energy sector

New U.S. and UK sanctions target Russia’s energy sector and supporting infrastructure. On January 10, 2025, the United States and the United Kingdom imposed additional sanctions against Russia, with a focus on its energy...more

BIS seeks public comment on potential rule restricting the import and use of unmanned aircraft systems involving China, Russia and...

On January 3, 2025 the U.S. Department of Commerce’s Bureau of Industry and Security released an advanced notice of proposed rule-making seeking public input on the definition of “unmanned aircraft systems” and their...more

New DOJ rule limits cross-border data transfers to protect national security

The Department of Justice (DOJ) has issued a final rule limiting data transfers to China, Russia, and other designated “countries of concern.” The rule establishes a new national security program that bans specific types of...more

U.S. Appeals Court limits OFAC’s sanctions authority in cryptocurrency mixer case

The Fifth Circuit held that Tornado Cash, open-source computer code known as an immutable “smart contract”, is not “property” and thus cannot be subject to blocking sanctions pursuant to IEEPA and EO 13694....more

U.S. Treasury announces new sanctions targeting Russian banks, warns foreign financial institutions from using Russian alternative...

The U.S. Department of the Treasury’s Office of Foreign Assets Control has designated dozens of Russian banks including Gazprombank and issued an alert warning foreign financial institutions of the risk of U.S. sanction for...more

BIS, OFAC, and U.S. State Department target Russia’s military and defense-industrial base

On October 30, 2024, the US government imposed additional trade controls to target procurement networks supporting Russia’s military and defense-industrial system. These additional trade controls include sanctioning 400...more

DOJ proposes regulations limiting certain data transfers to protect national security

The U.S. remains on course to restrict a broad range of cross border data transfers to China, Russia, and other designated countries. On October 21, 2024, the Department of Justice (DOJ) issued a Notice of Proposed Rulemaking...more

U.S. proposes revisions to “defense service” definition and related export controls

On July 29, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) issued a proposed rule to revise the definition of “defense service” and the scope of related controls under existing International...more

Proposed BIS rules target end users and uses, and U.S. person activity in specified countries

On 29 July 2024, the U.S. Department of Commerce’s Bureau of Industry and Security issued two proposed rules that would impose broad new license requirements on items subject to the Export Administration Regulations. The...more

BIS issues guidance on addressing diversion risk

On July 10, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its Guidance to Industry on BIS Actions Identifying Transaction Parties of Diversion Risk (the Guidance) designed to help...more

OFAC issues new standards for submissions and supporting documents

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has issued guidance on best practices for submitting information and documents in response to OFAC administrative subpoenas, requests for...more

Significant new measures against Russia issued by US Departments of Treasury, State, and Commerce

On 12 June 2024, the US Departments of Treasury, State, and Commerce imposed new restrictions targeting Russia, including: (i) restricting the provision of certain information technology and software services to Russia...more

OFAC issues interim final rule amending blocked property and other reporting requirements

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an interim final rule set to take effect August 8, 2024, which amends the Reporting, Procedures, and Penalties Regulations (the “Regulations”)...more

U.S. Commerce Department issues antiboycott compliance advisory on Turkey

On May 15, 2024, the U.S. Commerce Department’s Bureau of Industry and Security issued an antiboycott compliance advisory regarding the Turkish government’s announcement that it will suspend all imports and exports to and...more

BIS and DDTC take steps to update U.S. export controls to support AUKUS

In mid-April, the U.S. Departments of Commerce and State took a series of related actions to support implementation of the Australia, UK, and U.S. Trilateral Security Partnership. On April 19, 2024, BIS issued an Interim...more

BIS Issues License Exception MED for Russia, Belarus, Crimea, and covered regions of Ukraine

On April 29, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule to add a new license exception for medical devices (License Exception MED) to authorize the export, reexport, and...more

White House issues executive order on access to US sensitive personal data by countries of concern

The Biden Administration has issued an executive order to curtail access by China, Russia, and other countries of concern to Americans’ sensitive personal data. The Department of Justice and other agencies are tasked to take...more

U.S., EU, and UK expand sanctions to mark the second anniversary of Russia’s war in Ukraine

Following the death of political activist Aleksey Navalny and to mark the second anniversary of Russia’s invasion of Ukraine, the United States, EU and UK adopted a series of amendments to their respective economic sanctions...more

BIS further enhances voluntary self disclosure process for minor or technical violations

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) has further updated its voluntary self-disclosure (VSD) process by establishing streamlined procedures for minor or technical violations of the Export...more

New Russia sanctions target foreign financial institutions and imports of certain products

On December 22, 2023, President Biden issued a new Russia-related Executive Order (“EO”) targeting foreign financial institutions (“FFIs”) that support Russia’s military-industrial base. The new EO allows the U.S. government...more

BIS Issues Three New Rules To Ease Certain Export Licensing Requirements

On December 8, 2023, the Bureau of Industry and Security (BIS) issued three separate rules to amend the Export Administration Regulations (EAR) to liberalize several categories of export licensing requirements and make...more

Significant new U.S., UK and EU measures mark anniversary of Russia’s invasion of Ukraine

On 24 February 2023, the U.S. intensified its sanctions on Russia and released new trade control measures targeting key sectors, evasion efforts, and military supplies. Taken together, the additional sanctions, export...more

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