On December 2, 2022, the U.S. Department of Commerce released the highly-anticipated preliminary findings of its investigation into alleged tariff circumvention efforts by Chinese and Southeast Asian manufacturers of solar...more
On December 15, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) designated several individuals and entities to the Specially Designated Nationals and Blocked Persons (“SDN”) List,...more
On December 2, 2022, the United States, along with other G7 nations, including the European Union and Australia, adopted a price cap of $60 per barrel on seaborne crude oil of Russian Federation origin. The cap prevents firms...more
GL 13. On November 21, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued General License (“GL”) 13C related to the Russian Harmful Foreign Activities Sanctions Regulations,...more
On November 18, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 54 related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part...more
On November 14, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 40C related to the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR Part 587...more
G7 leaders agreed last month to implement a price cap on Russian oil sales starting December 5, 2022. In conjunction with the G-7 agreement, on October 31, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets...more
U.S. Sanctions In response to Russia’s attempt to annex parts of sovereign Ukrainian territory, G7 Leaders issued a statement on September 23, 2022 condemning Russia’s sham referenda and noting their collective readiness to...more
A lot has happened since our last update. Apologies to our readers for the delay to publish this Update. Each time we were ready to go to press, OFAC published a new action. Following the recent United Nations General...more
Russian Oil Price Cap -
The G7 has agreed to a U.S.-led coalition to impose a price cap on Russian oil exports to stem Russian profits from sales of oil to fuel its war efforts against Ukraine. On September 2, 2022, the...more
On August 19 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended Russia-related General License (“GL”) 38A (GL 38A) and issued a new GL (GL 50) related to the Russian Harmful Foreign...more
On August 2, 2022 and August 3, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) amended two Russia-related General Licenses (“GLs”): (GL 40A) / GL 40B) and (GL 43A), (ii) issued two...more
On July 22, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) (1) issued two new Russia-related General Licenses (“GL”) (GL 45 and GL 46), (2) published two new FAQs (FAQ 1071 and FAQ...more
On July 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued four Russia-related General Licenses (“GL”) (GL 6B, GL 25C, GL 30A, and GL 44), published three amended FAQs (FAQ 967,...more
On June 21, 2022, the Uyghur Forced Labor Prevention Act (“UFLPA”) took effect and established the rebuttable presumption that any goods mined, produced, or manufactured wholly or in part in Xinjiang Uyghur Autonomous Region...more
Conflicts of laws between the United States and the People's Republic of China (“PRC”) leave manufacturers and importers in a vexing and complex situation when conducting bilateral business and trade. Both countries agree...more
On June 28, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued five new General Licenses (“GL”) (GL 39, GL 40, GL 41, GL 42, and GL 43), released a new determination prohibiting gold...more
On 22 March 2021, UK foreign secretary, Dominic Raab, speaking in respect of the human rights situation in Xinjiang, PRC, stated that is was ‘the largest mass detention of an ethnic and religious group since the second world...more
On June 14, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 8C (replacing GL 8B), which extends the temporary wind down period to December 5,...more
On May 5, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 31 (“GL 31”), which makes clear that U.S. Persons may continue to act in the Russian Federation to...more
On June 9, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published eleven new FAQs (FAQ 1058, FAQ 1059, FAQ 1060, FAQ 1061, FAQ 1062, FAQ 1063, FAQ 1064, FAQ 1065, FAQ 1066, FAQ 1067,...more
The solar industry received welcome news last week when President Biden invoked his emergency authority under Section 318(a) of the Tariff Act of 1930 to mute the impact of the Commerce Department’s anti-circumvention...more
On June 2, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Russia-related General License (“GL”) 25B, GL 36, GL 37, and GL 38....more
On May 3, 2022, the U.S. Securities and Exchange Commission (“SEC”) staff issued a sample comment letter to alert public companies to potential disclosure obligations relating to the impact of Russia’s invasion of Ukraine and...more
On May 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) updated three FAQs (FAQ 1034, FAQ 1035, and FAQ 1038). Specifically, OFAC amended its guidance on the meaning of the terms...more