U.S. OFAC Issues Temporary General Licenses for Transactions Involving Russian Financial Entities
The U.S. Office of Foreign Assets Control (OFAC) has issued two Russia-related general licenses, General License No. 99A and General License No. 100A, under Executive Order 14024.
General License No. 99A authorizes the wind down of transactions involving specific Russian entities, including the Moscow Exchange (MOEX), National Clearing Center (NCC), and the National Settlement Depository (NSD). This license allows such activities until October 12, 2024, provided payments to blocked entities are made into blocked accounts in accordance with the Russian Harmful Foreign Activities Sanctions Regulations.
General License No. 100A permits certain transactions related to the divestment of debt or equity, or the conversion of currencies, involving the same Russian entities. These activities are also authorized until October 12, 2024, and must involve non-U.S. persons who are not blocked under U.S. sanctions.
These licenses provide temporary relief for winding down or divesting transactions with these Russian financial entities, ensuring compliance with U.S. sanctions regulations.
Source: download (treasury.gov)
U.S. Adjusts Tariff Exclusions in Response to Updated Trade Regulations with China
The U.S. International Trade Commission (USITC) implemented changes to statistical reporting categories in the Harmonized Tariff Schedule of the United States (HTSUS), effective July 1, 2024. In response, the U.S. Trade Representative (USTR) made corresponding adjustments to two extended exclusions related to the Section 301 investigation into China’s practices regarding technology transfer, intellectual property, and innovation. These changes ensure alignment with the updated HTSUS categories.
Source: 2024-17360.pdf (federalregister.gov)
BIS Fines Pennsylvania Firm $5.8 Million for Exporting Items to China’s Military Programs
The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) imposed a $5.8 million penalty on an American Swiss-domiciled technology company for illegal exports of low-level items to Chinese entities linked to hypersonics, UAVs, and military electronics. The company violated U.S. export controls by shipping $1.74 million worth of items, such as wires and circuit-board connectors, to Chinese parties on the BIS Entity List. These violations occurred between December 2015 and October 2019. The penalty was mitigated due to the corporation’s voluntary disclosure and cooperation with BIS’s investigation. This action supports the mission of the Disruptive Technology Strike Force to prevent adversaries from acquiring technologies that could enhance military capabilities.
- For more information, please visit https://www.bis.gov/enforcement.
Source: Guidance-for-Complying-with-BIS-Letters-Identifying-Transaction-Parties-of-Diversion-Risk_v8.pdf
BIS Publishes New Export Control Compliance Resources for the Academic Community
The Department of Commerce’s Bureau of Industry and Security (BIS) has released new compliance resources for the academic community to enhance their adherence to export controls. These resources include a compliance note on voluntary self-disclosure trends and a comprehensive compendium of export compliance tools. The compliance note outlines common export control violations by academic institutions over the past decade and suggests improvements such as better training and internal controls. The compendium provide a detailed guide to integrating export control requirements into daily operations, helping universities reduce the risk of violations. These efforts are part of BIS’s ongoing Academic Outreach Initiative, which aims to balance open research environments with national security protections through strategic engagement and training. Academic institutions are encouraged to report suspected violations through BIS’s tip portal, hotline, or email.
Source: BIS Publishes New Export Control Compliance Resources for the Academic Community
