Quarterly Trade Compliance Update – October 2023
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs.
Below is a summary of events this past quarter:
- Most notably, OFAC provided Venezuela with sanctions relief through a number of General Licenses. General License 44 authorizes transactions with the Venezuelan oil and gas industry, including transactions with PdVSA, subject to certain limitations. These licenses are contingent on the Venezuelan Government’s compliance with various agreements with the U.S.
- BIS strengthened export controls related to the provision of semiconductor technology with China.
- OFAC issues guidance related to Russian sanctions and its impact on the maritime industry, titled “Advisory for the Maritime Oil Industry and Related Sectors.”
- The unfortunate conflict in the Middle East will likely lead to new sanctions and export controls. BIS also recently finalized an enforcement action related to anti-boycott violations, and we would expect anti-boycott enforcement to be more of a focus, especially with regards to Israel. Companies should assess their business in this region and be proactive.
About the document:
This handy one-pager is designed to be used by our clients to provide a quick reference guide for the complex topics of trade sanctions and export control regulations. The goal is to briefly summarize key points for each program.
This document can be especially useful for non-lawyers and non-compliance officers. Some of our clients distribute the document to the sales and operations teams, or hang it with other legal and compliance material somewhere in the office. Many front-line employees need to know enough about sanctions to identify red flags and then engage legal and compliance as needed. We’ve unfortunately seen unwitting violations due to a lack of education or a lack of reference materials.