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To expand the reach of U.S. sanctions, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) on March 21 to require a license for the export, reexport, or transfer (in-country) of all items “subject to the EAR” when a party to the transaction is blocked under one of 14 U.S. sanctions

After Venezuela’s government and its political opposition agreed on electoral guarantees for 2024 presidential elections, the Office of Foreign Assets Control (OFAC) issued four general licenses suspending select sanctions:

  • General License 44 temporarily authorizes all transactions related to Venezuelan oil and gas sector operations, including producing, lifting, selling, and exporting oil or gas from Venezuela and new investment in oil or gas sector operations. The authorization includes transactions involving Petróleos de Venezuela, S.A. (PdVSA) or any entity in which PdVSA directly or indirectly owns a 50% or greater interest.

    The license expires on April 18, 2024. OFAC will only renew the license if Maduro’s government follows through with its commitments and continues taking measurable steps toward democratic elections in 2024.

  • General License 43 authorizes transactions involving CVG Compania General de Mineria de Venezuela CA (known as Minerven), the state-owned gold mining company.
  • General License 3I and General License 9H remove the secondary market trading bans on buying certain Venezuelan sovereign bonds, as well as pre-2017 PdVSA bonds or equity.

Continue Reading Overview: U.S. eases Venezuela-related sanctions after election deal

As a follow-on to last week’s quint-seal guidance, the Bureau of Industry and Security (BIS) published best practice guidance to help prevent high-priority items from being diverted to Russia. The latest guidance focuses on exports of the following high-priority items to counterparties in countries outside the Global Export Controls Coalition (GECC):[1]

HS Code

On Tuesday, the U.S., UK, Australia, Canada, and New Zealand—known as the “Export Enforcement Five” or “E5”—issued joint guidance to industry and academia on how best to identify Russian export control evasion tactics. The E5 coordinates with other members of the Global Export Control Coalition (GECC) on export controls specific to Russia. In addition to

On August 9, 2023, President Biden issued his much anticipated executive order on outbound U.S. investment in China, Hong Kong, and Macau (dubbed “reverse CFIUS”). The Treasury Department simultaneously released an advance notice of proposed rulemaking (ANPRM) related to the order. Public comments on the ANPRM will be accepted until September 28. The final rule

In October, the Bureau of Industry and Security (BIS) strengthened its antiboycott enforcement strategy. Last week, BIS made two additional enhancements to its enforcement strategy:

  • New Boycott Request Reporting Form. U.S. persons who receive boycott requests will now be required to identify the requesting party in addition to the country from which the

The U.S. Department of Justice (DOJ), Bureau of Industry and Security (BIS), and Office of Foreign Assets Control (OFAC) published their second Tri-Seal Compliance Note on July 26 summarizing their voluntary self-disclosure procedures for export control and sanctions violations. The Note highlights the potential benefits of self-disclosure, including significant mitigation of civil and criminal liability.

U.S. Customs and Border Protection’s (CBP) statistics confirm that the Uyghur Forced Labor Prevention Act’s (UFLPA) reach extends beyond imports from China. Though importers must remain focused on mitigating UFLPA compliance risks for Chinese-origin goods, CBP’s enforcement statistics offer a broader perspective on the scope of UFLPA-related detentions and seizures.

We highlight key takeaways and

The Court of International Trade continues to focus in on issues relating to Chinese-origin goods and on March 17 upheld the Section 301 tariffs on Chinese-origin goods identified on List 3 and List 4A. This decision comes despite the plaintiffs in In re Section 301 Cases arguing that the U.S. Trade Representative (USTR) violated the

The U.S Department of Commerce recently released the first of three expected Notices of Funding Opportunities under the CHIPS and Science Act of 2022. This act aims to develop the domestic semiconductor supply chain, provide jobs, restore the country’s leadership in semiconductor manufacturing, and advance U.S. national and economic security. 

In our latest alert, found on reedsmith.com