The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Our International Trade team comments on additional restrictions on trade with Cuba
I. Introduction - The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) is responsible for enforcing the Export Administration Regulations (EAR) — the rules that control the export, reexport, and even...more
In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus....more
UPDATE - On November 10, 2025, the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued its final rule staying the new Affiliates Rule, which will make any unlisted foreign entity owned, directly or...more
Each quarter, I send my clients a trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. In addition to a variety of ad hoc...more
Key Takeaways In a significant—but anticipated—change to the U.S. export control regime, the Bureau of Industry and Security (BIS) released an interim final rule amending the Export Administration Regulations (EAR) by...more
On September 30, 2025, the Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the Export Administration Regulations (EAR) to expand end-user controls and address diversion risks associated...more
On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a long-anticipated interim final rule (IFR) amending the Export Administration Regulations (EAR) to extend Entity List and...more
On September 29, 2025, the United States significantly expanded the reach of export controls. The U.S. Department of Commerce's Bureau of Industry and Security ("BIS") released an interim final rule, that applies Entity List...more
The U.S. Commerce Department has expanded export control sanctions by extending them to 50% or more-owned affiliates of restricted parties. This development has a particularly significant impact on China-related export...more
The Affiliates Rule automatically extends the US Department of Commerce’s Entity List and Military End-User (MEU) List to entities owned 50% or more by entities on either list. On September 29, 2025, the US Department of...more
On August 28, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule relaxing export controls on Syria in response to the June 30, 2025 Executive Order (EO) 14312 “Providing for the...more
On June 11, the US Department of Commerce, Bureau of Industry and Security (BIS) announced the release of two General Authorizations, accompanied by additional Frequently Asked Questions (FAQs) related to the January 16...more
On May 23, 2025, General License 25 (“GL 25” or the “General License”) was issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), suspending a wide array of sanctions against Syria....more
General License (GL) 25 authorizes transactions previously prohibited by various regulations. Specifically, Section (a) broadly authorizes activities previously prohibited under the Office of Foreign Asset Control (OFAC)’s...more
President Trump announced plans to relax sanctions against Syria during his recent trip to the Middle East, where he visited with the country’s President, Ahmed al-Sharaa. ...more
In its continuing response to Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert summarizes...more
In a continued effort to hinder Russia’s ongoing invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia and Belarus. This alert...more
The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months....more
On September 6, 2024, the Bureau of Industry and Security (BIS) issued an interim final rule (the September 6 IFR) implementing new and revised export controls relating to emerging or critical technologies in the fields of...more
In its continuing response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic...more
In a continued effort to hinder Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. ...more
In response to Russia’s invasion of Ukraine, the U.S. government has deployed a whole-of-government approach to impose sanctions and tighter export controls on Russia. This alert summarizes key economic sanctions imposed by...more
On July 18, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) amending the U.S. Export Administration Regulations (EAR) so that certain technology and software...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
In conjunction with the Group of Seven (G7) leaders meeting in Italy earlier this month, key jurisdictions issued the latest in a series of coordinated economic restrictions on Russia in light of its invasion of Ukraine in...more