The deadline to file OFAC’s Annual Report of Blocked Property (“ARBP”) is approaching fast. All “U.S. persons” — including U.S. financial institutions, companies, and individuals — who hold property blocked pursuant to any OFAC sanctions program should take a moment to assess their reporting obligations, as set forth in 31 C.F.R. § 501.603.
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Key Takeaways: The Bureau of Industry and Security (“BIS”) issued a temporary final rule under the Defense Priorities and Allocations System (“DPAS”) that restricts exports of shredded lithium-ion battery scrap containing cathode material, known as “black mass,” as well as tungsten and other waste by U.S. entities. Published on August 6, 2026, and effective immediately
On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List, established through the Secure and Trusted Communications Networks Act to include foreign-produced connected power inverters and advanced robotic devices. The designation of these products to the Covered List follows an Executive Branch national security determination that they “pose unacceptable risks to
Key Takeaways: The UAE’s reclassification to Country Group A:5 in the U.S. Export Administration Regulations (“EAR”) is one of the most significant expansions of U.S. export licensing flexibility extended to a Middle Eastern partner in recent years. Exporters should promptly assess whether existing licensed shipments or pending BIS applications can now be restructured under a
On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR)
On April 14, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela General License 56, “Authorizing Commercial-Related Negotiations of Contingent Contracts with the Government of Venezuela” (GL 56), and Venezuela General License 57, “Authorizing Financial Services Transactions Involving Certain Venezuelan Banks and Government of Venezuela Individuals” (GL
On March 23, 2026, the Federal Communications Commission (FCC) updated its Covered List—a list of communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons—to include consumer-grade routers produced in a foreign country, absent an exemption granted by the U.S. Departments of
On March 18 and 19, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued two new Venezuela-related general licenses: General License No. 52 (GL 52), authorizing most previously prohibited transactions involving Petróleos de Venezuela, S.A. (PdVSA) and General License No. 5V (GL 5V), authorizing further transactions related to the
Over the last two months, OFAC has issued and updated a series of general licenses and Frequently Asked Questions (FAQs) that allow for a variety of activities in the Venezuela oil, gas, petrochemical products, electricity, and gold sectors when they involve persons sanctioned pursuant to the Venezuela sanctions regulations, including the Government of Venezuela
On February 26, 2026, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) reached an administrative enforcement settlement with Teledyne FLIR LLC and its affiliates FLIR Optoelectronic Technology (Shanghai) Co. Ltd. and Teledyne FLIR Commercial Systems, Inc. d/b/a Teledyne FLIR OEM, (together, “Teledyne FLIR”), imposing a $1,000,000 civil penalty to resolve alleged violations