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Publications, Presentations & Quotes

Issuance of Amended Venezuela-related General Licenses

April 16, 2019

On March 8, 2019, OFAC issued amended General Licenses 3D and 9C related to Venezuela sanctions, extending the wind down periods in relation to financial contracts and other agreements involving certain bonds and Petróleos de Venezuela, S.A. (PdVSA), along with its subsidiaries.

Introduction of the ​Correspondent Account or Payable-Through Account Sanctions

April 16, 2019

On March 14, 2019, ​ OFAC announced the replacement of the List of Foreign Financial Institutions Subject to Part 561 (the "Part 561 List") with the List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (the “CAPTA List”). The CAPTA List contains identifying information of foreign financial institutions for which the opening or maintaining of a correspondent account or a payable-through account in the United States is prohibited or is subject to one or more strict conditions.

OFAC Extends Expiration Date of General License Related to PDVH and CITGO

April 16, 2019

On March 14, 2019, OFAC extended the expiration date of a general license related to PDV Holding, Inc. (PDVH), and CITGO Holding, Inc.  General License 7A provides an 18-month authorization that renews automatically on a monthly basis, which will enable CITGO to maintain operations in markets that are based on long-term planning and contractual commitments.

Wassenaar Arrangement 2017 Plenary Agreements Implementation (Final Rule)

October 30, 2018

On October 24, 2018, the Bureau of Industry and Security (BIS) revised the Commerce Control List (CCL) and EAR to update the Wassenaar Arrangement List of Dual-Use Goods and Technologies following changes decided upon during the December 2017 Plenary meeting. This final rule amends over fifty (50) ECCNs, License Exceptions APR, ENC, and STA, Definitions, the WA Sensitive and Very Sensitive Lists, and Regional Stability Controls.

BIS Issues Revised Process on Aluminum and Steel Exclusion Requests

September 7, 2018

As a result of comments received from the March 19 rule on remedies to the actions taken by President Trump’s issuance of Proclamations 9704 and 9705 to protect national security from threats resulting from imports of aluminum and steel, the Department of Commerce instituted a new process, effective September 11, for submitting objections to exclusion requests. BIS expects the revisions to the rule to make significant improvements to the current process for submitting tariff exclusion requests.

BIS Amends 17 ECCNs for MTCR Changes

August 30, 2018

On August 30, the Bureau of Industry and Security (BIS) amended the Export Administration Regulations to reflect changes to the Missile Technology Control Regime (MTCR) Annex that were agreed to by MTCR member countries in 2017. This final rule updates the following seventeen ECCNs: 1B117, 1B118, 1C111, 1C118, 2B109, 2B120, 2B121, 2B122, 6A107, 7A105, 7A107, 7A116, 9A012, 9A101, 9A115, 9A515, and 9A610.

News & Events from Jamie Joiner - Update on Iran Sanctions and More!

August 23, 2018

This newsletter features four articles entitled, "Executive Order is Issued to Reimpose Certain Iran Sanctions," "Additional Updates on China Tariffs," "Trump Administration Signs Export Controls Act," and "U.S. Government Issues Advisory of Risks for Businesses with Supply Chain Links to North Korea." View Newsletter→

Update on China Tariffs

August 8, 2018

The U.S. Trade Representative (USTR) recently announced that it has finalized the second list of tariff codes, covering an estimated $16 billion in Chinese imports, that will be subject to an additional 25% duty rate.  CBP will begin collecting these tariffs starting on August 23, 2018. The USTR also announced that it is extending the public comment period on the third list of tariff codes, covering approximately $200 billion in Chinese imports, that would have been subject to an additional 10% duty.  In response to President Trump’s recent request that the additional duty rate be raised to 25%, the USTR has extended the public comment period to accept feedback on this potential increase.  The comment period will now be extended to September 6, 2018.

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