As Russian Energy Week concluded last week, Western governments strike to the heart of Russia’s energy sector with sanctions packages to cut of revenue that funds Russia’s continued war against Ukraine. Three significant packages were announced in October 2025: the U.S.’s sanctions targeting the Russian energy sector, the UK’s latest sanctions against the Russian oil industry, and the EU’s 19ᵗʰ package of sanctions.Continue Reading Striking Russian Oil and The Ripple Effects
Update (November 2025): BIS suspended implementation of the Affiliates Rule for one year, temporarily reversing the extension of Entity List and MEU-related controls to foreign affiliates that are 50% or more owned by listed entities. In a final rule effective November 10, 2025, BIS stayed the interim rule’s amendments to the EAR until November 9, 2026, absent further extension. During the suspension period, the EAR reverts to the prior “legally distinct” test, meaning foreign affiliates are not automatically covered solely by virtue of 50% ownership. The suspension comes as result of trade negotiations with China, which we discuss our recent blog series on U.S. Trade in Asia.Continue Reading Not Your Usual Monday: BIS Adopts 50 Percent Rule for Entity List, MEU List & Related EAR Controls
The pace of U.S. regulatory changes regarding Syria continues to increase. Building on our previous posts (“Syria-ous Changes for Middle East Business?” and “Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means”), we describe below the recent developments that have resulted in significant easing of export controls.Continue Reading Keeping an EAR Out for Syria: BIS Reduces Export Controls
Key Takeaways
The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we outlined the initial steps taken by the U.S., EU, and UK to relax longstanding sanctions on Syria. Since then, the U.S. has introduced additional measures aimed at promoting commercial re-engagement, although several restrictions remain in place. Companies interested in doing business with Syria must stay current on evolving export control, sanctions, and compliance requirements.Continue Reading Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means
In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria
On July 22, 2024, the Department of Treasury, Office of Foreign Assets Control (OFAC) announced a significant planned extension to its recordkeeping requirements, which will increase the retention period from five to ten years. OFAC expects to publish an interim final rule to provide an opportunity to comment. The change will increase compliance obligations for entities engaged in transactions subject to U.S. sanctions.Continue Reading SoL Long to Short Limits: The Sequel — A Decade of Recordkeeping and Enforcement
On June 12, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new measures targeting Russia’s financial infrastructure, including:Continue Reading OFAC Tightens Russia Sanctions; BIS Cracks Down on Diversion
In a bold move to tighten its sanctions enforcement, the EU rolled out Directive 2024/1226, establishing minimum rules for defining criminal offenses and penalties related to the violation of EU sanctions. Effective May 19, the Directive mandates Member States to incorporate its provisions into their national legislation within 12 months.Continue Reading Walking the Tightrope: EU’s Sanctions Enforcement Directive Puts Violators on Notice
On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction programs.Continue Reading No More Postcards to OFAC in 2024: Unpacking OFAC’s New Reporting Procedures
Effective April 24, the statute of limitations (“SoL”) under the International Emergency Economic Powers Act (“IEEPA”) and the Trading with the Enemy Act (“TWEA”) has been extended from five to ten years. It would have been easy to miss this change, buried within a supplemental emergency appropriation bill (H.R. 815) signed into law by President Biden on April 24, 2024, but its impacts will be profound for entities facing internal or government investigations for sanctions violations.Continue Reading Say SoL Long to Short Limits: Doubling Down on the Sanctions Statute of Limitations