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Fenwick & West LLP

BIS Suspends the Affiliates Rule, Lifting Restrictions on Restricted Party Affiliates

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On November 10, 2025, the United States Department of Commerce, Bureau of Industry and Security (BIS) announced a one-year suspension of the “Affiliates Rule,” which imposed U.S. export control restrictions on entities 50...more

K&L Gates LLP

United States Imposes Sanctions on Russian Energy Companies

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On 22 October 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two of Russia’s largest energy companies, Rosneft and Lukoil, as well as numerous of their subsidiaries, on the...more

Goodwin

Digital Currency & Blockchain Quarterly Litigation Update - November 2025

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Welcome to Goodwin’s Digital Currency & Blockchain Quarterly Litigation Update, in which our Chambers-ranked global team of specialists shares highlights and key litigation and enforcement updates that are shaping the...more

Hughes Hubbard & Reed LLP

US Sanctions in a Snap: Developments In Sanctions - October 2025

Hughes Hubbard’s “Sanctions in a Snap” is intended to provide a clear and concise summary of recent developments from the Office of Foreign Assets Control (OFAC). We hope you find it helpful in assessing U.S. economic...more

ArentFox Schiff

Was It a Bird, Was It a Plane? No, It Was the BIS Affiliates Rule!

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It’s hard not to experience whiplash with export controls recently. A little over a month ago, the Bureau of Industry and Security (BIS) announced the new Affiliates Rule, which took effect immediately on September 29....more

Stankie Law

Quarterly Trade Compliance Update – November 2025

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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

Holland & Knight LLP

U.S. Sanctions Colombia's President Under Global Illicit Drug Trade Program

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 24, 2025, designated the Republic of Colombia's sitting president, Gustavo Francisco Petro Urrego (Petro), pursuant to Executive Order (EO)...more

Thompson Coburn LLP

57. October 22, 2025 | Trump Administration Blocks Major Russian Oil Firms

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In response to Russia’s unprovoked invasions of Ukraine in March 2014 and February 2022, the Department of Treasury implemented various sanctions on Russian entities....more

Pillsbury - Global Trade & Sanctions Law

OFAC Designates Rosneft and Lukoil in Significant Expansion of Sanctions Targeting Russia’s Energy Sector

On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced significant new sanctions for Russia’s energy sector, designating Rosneft Oil Company (Rosneft) and Lukoil OAO...more

Alston & Bird

OFAC Sanctions Major Russian Oil Companies

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On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed full blocking sanctions on Russia’s two largest oil companies—Rosneft and Lukoil—and several of their subsidiaries....more

Goodwin

Crude Awakening: United States Sanctions Rosneft and Lukoil

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On October 22, 2025, the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury designated OJSC Rosneft (Rosneft) and Lukoil OAO (Lukoil) on the List of Specially Designated Nationals and Blocked Persons...more

Stankie Law

OFAC Increases Sanctions on Rosneft and Lukoil, Adding Both to the SDN List

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On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued full blocking sanctions on Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”)...more

Paul Hastings LLP

US Imposes Comprehensive Sanctions and Export Controls Restrictions on Lukoil and Rosneft

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On Wednesday of last week, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took a significant further step to increase economic pressure on Russia in connection with the war in Ukraine, sanctioning...more

Eversheds Sutherland (US) LLP

The US Joins the UK in Placing Comprehensive Sanctions on Rosneft and Lukoil

On October 22, 2025 the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Open Joint Stock Company Rosneft Oil Company (Rosneft) and Lukoil OAO (Lukoil), placing both companies, including all...more

WilmerHale

Understanding the Impact of Different Terrorism Designations: A Look at Recent and Potential Administration Actions

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In late September, President Trump issued an executive order designating “Antifa” as a “Domestic Terrorist Organization.” As we have described in a previous client alert, the President soon thereafter also issued a National...more

Miller Canfield

BIS Expands Export Controls with New Affiliates Rule

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On September 29, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a pivotal interim final rule under the U.S. Export Administration Regulations (“EAR”) significantly broadening the scope...more

BakerHostetler

Weekly Blockchain Blog - October 2025 #3

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Group of Major Global Banks Exploring Stablecoin Focused on G7 Currencies On Oct. 10, a major French multinational bank announced that a group of leading international banks is jointly exploring the potential issuance of...more

King & Spalding

Trump Administration Expands Export Controls Restrictions to Non-U.S. Entities Owned by Restricted Parties

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The Interim Final Rule significantly expands the number of new and unlisted non-U.S. entities subject to U.S. export controls restrictions...more

DLA Piper

Enforcement Risks Increase Under BIS’s New 50-percent Ownership Rule for Entity List, MEU, and SDN Affiliates

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The US Commerce Department’s Bureau of Industry and Security (BIS) published an interim final rule (IFR) on September 30, 2025, extending export restrictions to entities or affiliates that are 50-percent or more directly or...more

Holland & Knight LLP

BIS Expands Impact of U.S. Export Controls with 50 Percent Rule

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The U.S. Department of Commerce Bureau of Industry and Security (BIS) published a much-anticipated interim final rule (IFR) on Sept. 30, 2025. The IFR makes foreign entities that are owned 50 percent or more, directly or...more

DLA Piper

Expansion of end-user controls to cover affiliates: BIS adopts 50 percent ownership rule for Entity List, Military End User List,...

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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

Latham & Watkins LLP

US Commerce Department Adopts Affiliates Rule Expanding Export Restrictions

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This measure significantly expands the scope of Entity List and Military End-User List restrictions, imposing heightened diligence obligations and complicating EAR compliance....more

Katten Muchin Rosenman LLP

U.S. Bureau of Industry and Security Amends Export Administration Regulations to Add 50% "Affiliate" Rule for Entity and Military...

On Sept. 29, 2025, the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") issued a new interim final rule (the "Rule") that amends the Export Administration Regulations ("EAR"). Under the Rule, any foreign...more

Blank Rome LLP

BIS Adopts Long-Awaited "Affiliate Rule"

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The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule on September 29, 2025, adopting an “Affiliate Rule” under the Export Administration Regulations (“EAR”) based on, and...more

Mayer Brown

New US Commerce Department Global License Requirements for Transactions Involving Affiliates of Listed Entities

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The US Department of Commerce, Bureau of Industry and Security (BIS) on Monday, September 29, 2025, released the Affiliates Rule, which draws unnamed entities around the world into BIS’s entity-specific controls. BIS intends...more

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