On August 13, 2014, the Office of Foreign Assets Control (“OFAC”) revised its guidance on the status of entities owned by persons designated on the Specially Designated Nationals List (“SDN List”). Under the new guidance, OFAC will consider an entity to be blocked if it is 50 percent or more owned, directly or indirectly, in … Continue Reading
Effective August 6, 2014, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new regulations, identified as the “Russian Industry Sector Sanctions,” restricting exports and other transfers of certain items subject to the Export Administration Regulations (“EAR”) that may benefit Russia’s energy sector. Newly added EAR section 746.5 imposes licensing requirements … Continue Reading
The European Union has made further additions to the list of sanctioned parties under the regime put in place in response to the Russian Federation’s actions in the Crimea (Regulation 269/2014 and subsequent amendments). On 12 May 2014, the Council of the European Union published Regulation 477/2014, which added an additional 13 individuals to the … Continue Reading
This post was written by Joelle E.K. Laszlo. What if you issued a general license and no one used it? The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has faced such a conundrum since March 2010, when it published a final rule amending U.S. regulations on Cuba, Iran, and the Sudan to … Continue Reading
This post was written by Joelle E.K. Laszlo. In an effort to update U.S. policy to “enhanc[e] support to allies and friends, improv[e] efficiency in licensing, and reduc[e] unintended consequences,” the State Department (“State” or “the Department”) has proposed to revise the definition of “defense service” in the International Traffic in Arms Regulations (“ITAR”). While … Continue Reading
