On December 5, 2022, the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) announced a $60 per barrel price cap on maritime transfers of Russian-origin crude oil. The final cap level is being implemented multilaterally by the Price Cap Coalition, which include the Group of 7 (G7) nations…
On November 2, 2022, Assistant Secretary of the U.S. Department of Commerce Thea Rozman Kendler answered questions on the Bureau of Industry and Security’s (BIS) October 13 interim final rule (“the Rule”) regarding restrictions on certain advanced computing integrated circuits and semiconducting manufacturing items exported to the People’s Republic of…
The U.S. Department of Treasury recently released Enforcement and Penalty Guidelines (Guidelines) that outline conduct violating the Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. Specifically, these Guidelines, the first of their kind, outline CFIUS’ process and practical considerations when deciding whether to impose penalties and how…
Various reports indicate that the Group of Seven nations (G7) will announce its initial capped price for Russian-origin crude oil transported by maritime means (“seaborne”) this week. The cap will come into effect on December 5, 2022, for crude oil (including condensate) and February 5, 2023, for petroleum products. U.S.…
The EU has published its eighth package of measures and the UK has published a number of new regulations to implement previously announced measures. Split across four regulations, the EU’s eighth package: Introduces new export controls relating to Russia. In addition to existing export bans, it is now prohibited to…
On October 28, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued guidance on its October 7, 2022 interim final rule (Rule) that imposed new export controls on certain advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and semiconductor manufacturing items exported to…
On October 24, 2022, the U.S. Department of Treasury Office of Foreign Assets Control (OFAC) and Department of State (State) announced new sanctions designations for Nicaragua, targeting a key state mining company and amending Executive Order (E.O.) 13851 to expand the U.S. government’s authority to issue sanctions in reactions to…
On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule (the “Rule”) imposing sweeping new export controls targeting certain advanced computing integrated circuits (ICs), computer commodities that contain such ICs, and certain semiconductor manufacturing items intended for the People’s Republic…
In response to Russia/Ukraine conflict, and Belarus’ ensuing support for Russia, the United States and global allies have imposed sweeping sanctions and export control restrictions on both Russia and Belarus. These actions are discussed extensively in our prior publications. The sanctions and export controls restrictions especially target Russia and have…
On September 29, 2022, the U.S. government took an important step in its efforts to increase transparency, combat shell companies, and limit abuse of entities and trusts formed under U.S. state law. The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a final rule implementing provisions of the Corporate…