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This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. involving apparent violations of the U.S. embargo on Iran by a subsidiary in Turkey.  Under the agreement, Berkshire Hathaway agreed to pay over $4.1 million to settle allegations that the Turkish subsidiary exported 144 shipments of cutting tools

On October 16, 2020, the Bureau of Industry and Security (BIS) announced that exporters may request a six-month extension for export licenses set to expire on or before December 31, 2020.

BIS indicates that most requests for extensions will be reviewed and approved on an expedited basis within two to three business days, depending on

Last week, the United States expanded sanctions on Iran’s financial sector by designating 18 major Iranian banks as Specially Designated Nationals (SDNs) and authorizing additional future sanctions on the Iranian financial sector.  Non-U.S. companies and banks could be subject to serious U.S. secondary sanctions penalties for significant continued dealings with the designated Iranian financial institutions,

Last week OFAC extended its general license authorizing U.S. persons to wind down and divest from certain transactions with subsidiaries of the Xinjiang Production and Construction Corps (XPCC) until November 30, 2020.  OFAC extended the general license to give U.S. persons more time to exit dealings involving XPCC’s many subsidiaries, which play a significant role

Yesterday, the Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR) to further limit the ability of U.S. persons to book lodging in Cuba, import certain goods from Cuba, and participate in professional meetings or artistic and athletic events in Cuba.  The changes include the following:

  • The new rules prohibit U.S.

Post Update:

Over the weekend, the WeChat and TikTok bans were temporarily suspended.  On Saturday, the Commerce Department delayed implementation of the TikTok ban until September 28, 2020 after it was announced that Oracle would acquire TikTok’s U.S. operations.  On Sunday, a federal court separately issued a preliminary injunction against the implementation of the WeChat

On August 28, 2020, the U.S. Department of Defense (DOD) updated its list of “Communist Chinese military companies” that provide expertise and technological support to the Chinese military.  The list, which includes a number of large state-owned enterprises in China, does not impose sanctions or export restrictions on the listed companies, although some of the

Today the Bureau of Industry and Security (BIS) added 24 Chinese state-owned companies to the Entity List for their role in the construction of artificial islands in the South China Sea.  The Entity List prohibits the export, re-export, and transfer (in-country) of items subject to the Export Administration Regulations (EAR) to these companies without a

On August 20, the Bureau of Industry and Security (“BIS”) published a final rule (“final rule”) amending the Export Administration Regulations (“EAR”) to expand restrictions on transactions involving Huawei entities that are included on BIS’s Entity List (“designated Huawei entities”).  The newly expanded rule applies to a broader range of items produced outside of the

On August 20, 2020, the Bureau of Industry and Security (BIS) will publish a final rule confirming that the Entity List licensing requirements apply to all transactions in which a listed party plays a role – including where the listed party is the ultimate consignee, end-user, purchaser, or intermediate consignee.  The new rule formally codifies