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Rachel Schumacher is an associate in the International Trade and Government Contracts groups in Crowell & Moring’s Washington, D.C. office. Rachel’s practice focuses on transactions, investigations, and compliance and advisory matters involving a variety of government contracts and international trade issues.

On March 22, 2023, the Department of Defense (DoD) issued a proposed rule that would amend the Defense Federal Acquisition Regulation Supplement (DFARS) to require certain contractors to provide export authorizations to the Defense Authorization Management Agency (DCMA).

DCMA performs quality assurance reviews for manufacturing operations to ensure contractors have the appropriate systems in place

New U.S. and UK Sanctions Partnership: On October 13, 2022, the Office of Foreign Assets Control (“OFAC”) and the UK’s Office of Financial Sanctions Implementation (“OFSI”) announced that they had concluded multi-day meetings in London involving technical exchange of information between the two sanctions authorities.  The agencies have decided to enhance OFAC-OFSI cooperation further, including

On October 7, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) simultaneously published a final rule strengthening the antiboycott regulations in Part 766 of the Export Administration Regulations (EAR) (the “Final Rule”), as well as a memorandum on the new rule’s implementation (the “Final Rule Memo”), issued by the Assistant Secretary

EU Updates FAQS to Address Energy Security: On October 7, 2022, the EU updated two FAQs clarifying the impact of Council Regulation 833/2014 on the import, purchase and transfer of listed goods.  The EU clarified that Council Regulation 833/2014 prohibits the transfer of any listed goods if they originate in Russia or are exported from

Crude Oil and Petroleum Price Cap: On September 2 2022, the G7 Finance Ministers issued a statement demonstrating their intent to implement a price cap on Russian-origin crude oil and petroleum products.  The G7 countries plan to prohibit the provision of services that enable maritime transportation of these products unless the products are purchased

Russia Sanctions: This week the European Union designated three additional individuals.  Two of the individuals are members of the Duma who undermined the territorial integrity, sovereignty, and independence of Ukraine by voting in favor of a resolution regarding the need to recognize the so-called Donetsk People’s Republic and Luhansk People’s Republic.  The other sanctioned

Russia Sanctions: This week the United Kingdom updated the listings for several sanctioned persons by making 17 amendments to designated individuals and 10 amendments to designated entities.  The amendments included revisions to dates of birth, addresses, and descriptions.

General Licenses: On August 5, 2022, the United Kingdom issued general license (“GL”) INT/2022/2055384.  The

New UK Sanctions:On July 21, 2022, the UK introduced a new tranche of restrictions in the 14th amendment to its Russian Sanctions Regulations.  Several of the new restrictions are detailed below.

The UK prohibited UK persons from directly or indirectly providing accounting services, business and management consulting services, and public relations services to “

New UK Sanctions: On July 21, 2022, the UK introduced a new tranche of restrictions in the 14th amendment to its Russian Sanctions Regulations.  Several of the new restrictions are detailed below.

The UK prohibited UK persons from directly or indirectly providing accounting services, business and management consulting services, and public relations services to

Russia Sanctions: This week the United Kingdom designated several additional individuals, primarily for contributing to the spread of disinformation about Ukraine and promoting Russian actions in Ukraine, or for their affiliation with organizations that have spread disinformation relating to Ukraine, such as SouthFront and NewsFront.  The United Kingdom also designated United World International, an