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Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software

Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more

No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures

On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more

New Russia Sanctions Intensify Pressure on Banks Worldwide

On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated that the...more

Friday Development: New Sanctions and Export Controls to Address Russia’s Ongoing Aggression in Ukraine (Including the use of...

In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more

U.S. and Allies Impose Additional Russia Sanctions After Sham Annexations

In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia. U.S. Response On October 4, 2022, the U.S. government...more

The Next Four Years in International Business

Over the past few weeks, we have been speculating on the international trends and tides we expect to see in the next four years under a new U.S. presidential administration. So that you can enjoy our prognostications (before...more

How to Steal $10 Billion from Europe

Europe has come up with a nifty plan to help Iran buy and sell stuff outside the reach of U.S. sanctions. The problem is that the plan is a fraud magnet. How do we know? It’s been tried before, and the fraud was epic. The...more

Client Alert: Iran Sanctions Return

1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018. 2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated. 3....more

North Korea Sanctions Continue to Intensify

On September 11, 2017, the UN Security Council unanimously imposed new sanctions on North Korea. The move came only days after Pyongyang launched an underground nuclear test that may have been the detonation of a hydrogen...more

Our Armchair Santería on Cuba Policy: What Will President Trump do on Cuba?

According to reports published this week, the Trump Administration is preparing to release the results of its policy review on Cuba in the “coming weeks.” We don’t have a crystal ball (or a leaking insider). But we continue...more

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