Treasury's Office of Foreign Assets Control (OFAC) is issuing Venezuela-related General License 8M, "Authorizing Transactions Involving Petróleos de Venezuela, S.A. (PdVSA) Necessary for the Limited Maintenance of Essential Operations in Venezuela or the Wind Down of Operations in Venezuela for Certain Entities," and Venezuela-related General License 45A, "Authorizing Certain Transactions Involving Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos, S.A."  Additionally, OFAC is publishing an updated, related document "Frequently Asked Questions Related to the Suspension of Certain U.S. Sanctions with Respect to Venezuela on October 18, 2023."

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing an OFAC Compliance Communiqué: Guidance for the Provision of Humanitarian Assistance to the Palestinian People in response to questions from the NGO community and the general public on how to provide humanitarian assistance while complying with OFAC sanctions. Neither Gaza nor the West Bank are subject to jurisdiction-based sanctions or an embargo by OFAC.  Further, OFAC authorizes limited transactions with blocked persons to the extent such dealings are ordinarily incident and necessary to certain humanitarian activity,

Export-Import Bank of the United States announced a proposed transaction to assist in the rebuilding of Ukraine's rail network, and funds to build an electric airplane factory in Vermont. The …

The Department of State last week officially announced the Bureau of Arms Control, Deterrence, and Stability (ADS), the new name of the Bureau of Arms Control, Verification and Compliance. This …

Congress should consider creating a single export licensing system to strengthen export controls on China, the US-China Economic and Security Review Commission said in its annual report to Congress released last week. In its report, the commission urged Congress to consider a number of steps to make it more difficult for China to evade US controls. First, the report recommends that Congress hold hearings to evaluate the potential for establishing a single export licensing system.

The House Financial Services Committee passed 11 bills last week sanctioning Iran and Hamas, in response to the Tehran's role in funding Hamas militants responsible for the Oct. 7 attacks on Israel. Some bills sought to rein in the Biden administration's dealings with the Iranian regime. Others were meant to "ensure that any humanitarian assistance to Iran is not used to finance acts of terror," according to a press release from the committee. It remains to be seen if House Leadership has the discipline and motivation to bring the bills to a successful resolution in any measurable period of time.

House Foreign Affairs Committee Chairman Michael McCaul (R-Texas) wants to know the reasoning behind the Administration’s decision to lift sanctions on the Maduro regime in Venezuela. “The regime will enrich itself from this Administration’s sanctions relief while the Venezuelan people remain without a viable path for free and fair elections,” he wrote.

Assistant Secretary Matthew Axelrod of the Commerce Department’s Bureau of Industry and Security and Assistant Attorney General Matthew Olsen of the Justice Department’s National Security …

The Justice Department’s Environment and Natural Resources Division (ENRD) is prioritizing the investigation and prosecution of timber trafficking offenses, including through the recent creation of the TIMBER Enforcement Working Group. This has led to the largest-ever fine for timber trafficking, restitution to foreign countries for illegally sourced timber and insight into how trafficking works.

Assistant Secretary of Commerce for Export Administration Thea Kendler held a briefing November 6 to discuss the rules issued October 17th. She explained the new parameters, associated license requirements, the new notified advanced computing license exception, and some of the measures put into place to address possible circumvention of the controls.

The Office of Inspector General (OIG) for the Department of State has released a redacted report detailing its review of end-use monitoring (EUM) for U.S. security assistance in Ukraine. This follows the U.S. commitment of approximately $30 billion in aid since Russia's invasion in February 2022. Findings indicate that Embassy Kyiv conducted limited in-person EUM activities, supplemented by secondary procedures involving Ukrainian government assistance. No misuse of equipment was identified, and commitments from recipients remained unchanged post-invasion. However, challenges like security restrictions and ad-hoc reporting of battlefield losses were noted.

The House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, sent a letter to the United States Trade Representative, Ambassador Katherine Tai, …

The Justice Department prepared an Opinion Procedure Release for an unnamed U.S. company permitting payments to foreign officials despite potential conflict with the Foreign Corrupt Practices Act's anti-bribery provisions.

The Bureau of Industry and Security (BIS) is rescheduling the Update Conference on Export Controls and Policy from November 28–30, 2023 to March 27-29, 2024.

Britian's National Crime Agency has issued an alert warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime. Given the importance of the UK to the gold market, the NCA is warning of deliberate attempts are being made to launder sanctioned gold to mask its origin so that it can be hidden in supply chains and sold in the UK and around the world.

U.S. Customs and Border Protection officers seized a shipment of China-bound deuterium cylinders in Norfolk on October 18 for violating nuclear nonproliferation licensing laws. On August 22, CBP’s National Targeting Center (NTC) identified the deuterium on the manifest of a shipping container destined to China. CBP officers detained the deuterium, and the following day requested a licensing determination from the Bureau of Industry and Security. 

President Biden has continued for one year the investment restrictions placed on Chinese securities associated with the PRC's Civil-Military Fusion (CMF) industrial policy. The restrictions include tradeing is securities of Chinese firms in the defense sector, as well as entities deemed controlled by the Chinese Communist Party.

On November 7, the Financial Crimes Enforcement Network (FinCEN) issued a final rule that specifies the circumstances in which a reporting company may report an entity’s FinCEN identifier in lieu of information about individual beneficial owners. In response to commenter concerns that the reporting of entity FinCEN identifiers could obscure the identities of beneficial owners in a manner that might result in greater secrecy or incomplete or misleading disclosures, the final rule provides clear criteria that must be met in order for a reporting company to report an entity’s FinCEN identifier.

Commerce’s Bureau of Industry and Security (BIS) announced the imposition of a civil penalty of $44,750 against Forta LLC (Forta), a manufacturer of synthetic reinforcement fibers, located in Grove City, Pennsylvania, to resolve three violations of the antiboycott provisions of the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774) (antiboycott regulations). Forta voluntarily disclosed the conduct to BIS, cooperated with the investigation by BIS’s Office of Antiboycott Compliance (OAC), and took remedial measures after discovering the conduct at issue, all of which resulted in a significant reduction in penalty.

Treasury’s Financial Crimes Enforcement Network (FinCEN) and Commerce’s Bureau of Industry and Security (BIS) are issuing a new SAR key term to support financial institutions in reporting potential efforts to evade U.S. export controls beyond the Russia-related circumstances that were the focus of prior alerts.

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