Trade and Manufacturing Monitor
OFAC Publishes Guidance on Extension of Statute of Limitations and Recordkeeping Requirements
This blog post was drafted with assistance from Sean C. Church, Paralegal On July 22 nd, 2024, OFAC published a guidancedocument regarding the 21 st Century Peace through Strength Act’sextension of the statute of…
BIS Issues Guidance on Addressing Export Diversion Risks
On July 10, the Department of Commerce’s Bureau of Industry and Security (BIS) published guidance on how to identify parties that present a heightened risk of diversion to Russia’s military-industrial sector, as well…
Treasury Issues Proposed Rules on Outbound Investments to China and Solicits Comments
On June 21, 2024, the Treasury Department issued a Notice of Proposed Rulemaking (NPRM) setting out draft rules for regulating certain outbound U.S. investments. The NPRM incorporates feedback received by the Treasury…
Statute of Limitations for Sanctions Violations Increased to Ten Years
On April 24, 2024, the 21 st Century Peace Through Strength Act became law. Although the Act contains many key national security policies, including aid for Ukraine and Israel, one provision that has been overlooked is…
Commerce Initiates Rulemaking Targeting Foreign-Manufactured Technology Used In Connected Vehicles
On Thursday, February 29th,2024, the Department of Commerce (“the Department”) announced an advancenotice of proposed rulemaking (“ANPRM”), seeking public comments regardingnew potential regulations to “secure and…