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
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
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
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
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
1/23/2025
/ Bureau of Industry and Security (BIS) ,
China ,
Cybersecurity ,
Executive Orders ,
Export Controls ,
National Security ,
Risk Management ,
Russia ,
Supply Chain ,
U.S. Commerce Department ,
Unmanned Aircraft Systems
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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