The OverRuled: Russia Trade Controls Resource Center has been updated with the following actions:
- 23 Jul 2024 (OFAC):
The U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued its Notice of "Reporting Instructions under the Rebuilding Economic Prosperity and Opportunity for Ukrainians Act" (the "Act"). The Instructions require "financial institutions" (as defined in the reporting instructions) to report, "no later than August 2, 2024 or within 10 days of the detection of [covered] assets" and to the extent such assets have not already been reported to OFAC under separate reporting requirements, "(A) Funds and other property of (i) the Central Bank of the Russian Federation, (ii) the Russian National Wealth Fund, or (iii) the Ministry of Finance of the Russian Federation; or (B) any other funds or other property that are owned by the Government of the Russian Federation, including by any subdivision, agency, or instrumentality of that government." This applies only to property "located" at covered financial institutions.
The OverRuled: China Trade Controls Resource Center has been updated with the following actions:
- 24 Jul 2024 (BIS):
BIS corrected errors in the July 18, 2024 interim final rule on "standards-related activities," which inadvertently reverted changes introduced by the June 18, 2024 final rule. Specifically, BIS reintroduced language from the June 18 rule on the new regulatory framework for listing addresses on the Entity List.
- 17 Jul 2024 (BIS):
BIS expanded the existing authorization for "standards-related activities" under the EAR, which previously only covered the release of eligible software and technology to certain entities added to the Entity List. The expansion is intended to ensure that export controls and associated compliance concerns do not impede the participation and leadership of U.S. companies in legitimate standards-related activities.
Specifically, BIS made the following changes:
- Moving the authorization for "standards-related activity" from Section 744.11 to Section 734.10, such that eligible software and technology released for a "standards-related activity" are not subject to the EAR.
- Revising the existing definition of "standards-related activity" in two respects. First, the new definition clarifies that a "standards-related activity" includes activities conducted for an already "published" standard, in addition to those conducted with the intent to "publish" a standard. Second, BIS removed the phrase "with which compliance is not mandatory," which previously formed part of the description of "standards" under the authorization.
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