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Hiding in Plain Sight: New Ukraine and Israel Aid Package Includes Significant Changes to US Sanctions and Export Control Laws

On April 24, 2024, President Biden signed into law H.R. 815, an emergency appropriations package billed as authorizing $95 billion in foreign aid to Ukraine and Israel (the Act). While the Ukraine and Israel aid provisions...more

U.S. Agencies Caution Foreign-Based Persons on Extraterritorial Reach of U.S. Sanctions and Export Control Regulations

On March 6, 2024, the U.S. Departments of the Treasury, Commerce, and Justice jointly issued a Tri-Seal Compliance Note titled “Obligations of Foreign-Based Persons to Comply with U.S. Sanctions and Export Control Laws”...more

Global Jurisdictions Adopt New Price Cap on Russian Petroleum Products - New Guidance Creates Additional Compliance Expectations

Effective February 5, 2023, the Price Cap Coalition (the Coalition), consisting of the G7 nations, the European Union (EU) and Australia, set a price cap of $45 per barrel for “Discount to Crude” petroleum products of Russian...more

Global Jurisdictions Implement Russian Oil Ban and Price Cap Policy

A ban on services related to the maritime transport of Russian-origin crude oil sold above a pre-determined price cap of $60 per barrel began on December 5, 2022, with a similar price cap ban related to other Russian-origin...more

New Commerce Department FAQs Require Due Diligence by Exporters to Assess Chinese Military End Uses and Users

On June 29, 2020, the Commerce Department issued 32 Frequently Asked Questions (FAQs) concerning revision - effective as of the same date - to Part 744.21 of the Export Administration Regulations (EAR). As we discussed in a...more

COVID-19: FEMA Announces Additional Exemptions for Export Restrictions on PPE

On April 21, 2020, the US Federal Emergency Management Agency (FEMA) is due to publish a notification of exemptions (Notification) to the restrictions it has recently imposed on the export of five types of personal protective...more

OFAC Crystallizes Expectations for Sanctions Compliance

On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

OFAC and BIS Announce Further US Sanctions Authorizations and Export Licensing Policies for Cuba

The US Departments of the Treasury and Commerce are taking further action to implement President Obama's initiatives to normalize US-Cuba relations and to “engage and empower the Cuban people.” The measures announced...more

Colombian Companies Face New Compliance Challenges as Nation Ascends to World Economic Stage

When OFAC added Colombian sports franchise Envigado Fútbol Club to its sanctions list in June 2014, the news conjured up echoes of past dark days of “narco fútbol,” when the tentacles of organized crime touched the country’s...more

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