On April 18, 2024, the Departments of Commerce and the Treasury announced combined export control restrictions and economic sanctions against Iran for its attack on Israel on April 13, 2024. These actions are intended “to degrade and disrupt key aspects of Iran’s malign activity, including its UAV [Unmanned Aerial Vehicles] program and the revenue the
Russia
OFAC Again Extends Authorizations Under Russia General License 13
On April 12, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) again extended previous Russia-related General License (GL) 13 by issuing a revised GL 13I, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024,” which states that U.S. persons are authorized to pay taxes, fees, or import…
United States Bans Imports of and Services Related to Russian-Origin Aluminum, Copper and Nickel
On April 12, 2024, the Office of Foreign Assets Control (OFAC) signed a new determination under section 1(a)(i)(A) of Executive Order 14068 of March 11, 2022 as amended by Executive Order 14114 of December 22, 2023. According to this determination, the importation and entry into the United States, including importation for admission into a foreign…
USTR Releases 2024 National Trade Estimate Report on Foreign Trade Barriers
The Office of the U.S. Trade Representative (USTR) released on March 29, 2024, its annual National Trade Estimate Report on Foreign Trade Barriers (NTE Report) that addresses the status of foreign trade and investment barriers to U.S. exports worldwide. This is the U.S. government’s major annual report on the barriers to U.S. exports of goods…
BIS Amends EAR to Expand Export Controls on OFAC SDN-Listed Persons
On March 20, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule implementing restrictions under the Export Administration Regulations (EAR) on persons who have been designated and placed on the Specially Designated Nationals (SDN) List maintained by the Department of the Treasury’s Office of Foreign Assets Control (OFAC). Under Secretary…
U.S. Sanctions Hundreds of Entities to Mark the Second Anniversary of Russia’s Invasion of Ukraine
- More than 500 entities and individuals added to the Specially Designated Nationals and Blocked Persons List and nearly 100 added to the Entity List.
- Four new or updated general licenses issued by the Office of Foreign Assets Control to address wind-down and safety considerations.
- An expansion of the multilateral Common High Priority Items
U.S. Imposes New Sanctions on Russia to Commemorate Second Anniversary of Russia’s Invasion of Ukraine
On February 23, 2024, the eve before Russia’s full-scale invasion of Ukraine officially enters its third year, the United States issued another sanctions package against Russia, taking particular aim at Russia’s financial sector, energy production revenue streams, and military-industrial complex. Specifically, the package sanctions more than 500 entities and individuals by having them added…
OFAC Extends Authorizations Under Updated Russia General License 83A
On February 20, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) extended Russia-related General License (GL) 83 by issuing a revised version: GL 83A, “Authorizing Certain Transactions Related to Imports of Certain Categories of Fish, Seafood, and Preparations Thereof Prohibited by Executive Order 14068.” The modified GL 83A maintains the…
OFAC Issues Determinations to Prohibit Import of Russian-Origin Diamonds
On December 22, 2023, President Joseph Biden amended Executive Order (EO) 14068 by additionally authorizing the prohibition on the importation and entry into the United States of diamonds of Russian Federation origin. See Thompson Hine Update of January 2, 2024. The EO required that such a ban be implemented only after the issuance of…
OFAC Issues Oil Price Cap Compliance and Enforcement Alert Recommending Methods to Mitigate Evasion Risks
On February 1, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published an Oil Price Cap Compliance and Enforcement Alert to provide “[a]n overview of [five] key … evasion methods and [corresponding] recommendations for identifying such methods and [subsequently] mitigating their risks and negative impacts.” The price cap referenced by the…

