On January 13, 2026, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued a final rule, titled Revision to License Review Policy for Advanced Computing Commodities (the “BIS Rule”), that implements a more favorable license application review policy for exports from the United States of certain advanced computing
Continue Reading U.S. Commerce Department Revises License Review Policy for Exports of Certain Advanced Computing Commodities to China and Macau
New Sanctions Authorities in the FY 2026 NDAA
After passing the House the preceding week, the National Defense Authorization Act for Fiscal Year 2026 (FY 2026 NDAA) passed the Senate on December 17 by a vote of 77-20 and was signed into law by President Trump the following day. As is frequently the case, this annual “must pass”
Continue Reading New Sanctions Authorities in the FY 2026 NDAASenate Foreign Relations Committee Action on Russia and China-related Legislation
The government is officially closed, and the House of Representatives is in an extended recess, but the Senate keeps working.
On Wednesday October 22, the Senate Foreign Relations Committee held a business meeting to consider 19 bills and approve two nominations (Joel Rayburn to be Assistant Secretary of State for Near Eastern Affairs and Andrew Veprek to be Assistant Secretary of State for Population, Refugees and Migration). The bills focused mostly on Russia’s war in Ukraine, and on security concerns relating to China, and generally commanded bipartisan support. All of the bills were approved, though some were amended.
One of the more consequential bills was the “REPO Implementation Act”, S. 2918, sponsored by Sen. Whitehouse, and co-sponsored by, among others, Foreign Relations Committee Chairman Risch. This bill seeks to build on last year’s “Rebuilding Economic Prosperity and Opportunity for Ukrainians Act”, or “REPO Act”. That legislation granted authority to the President to confiscate the approximately $5 billion in immobilized Russian sovereign assets in the United States and provide that money to Ukraine and Ukrainian claimants as compensation for the injuries inflicted on them by the war. Continue Reading Senate Foreign Relations Committee Action on Russia and China-related Legislation
U.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions Package
On October 22, 2025, the U.S. government imposed property-blocking sanctions on Russia’s two largest oil companies, Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”), by designating these entities, as well as 34 Russia-based Rosneft and Lukoil subsidiaries, to the List of Specially Designated Nationals and Blocked
Continue Reading U.S. and UK Sanctions Target Russia’s Two Largest Oil Companies; EU Issues Significant New Russia and Belarus Sanctions PackageU.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed Entities
On September 29, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued an interim final rule titled Expansion of End-User Controls to Cover Affiliates of Certain Listed Entities (the “Affiliates Rule”).
Click here to read the full alert on cov.com
Continue Reading U.S. Department of Commerce Expands End-User Controls to Cover Affiliates of Certain Listed EntitiesReimposition of UN-Mandated Sanctions Against Iran and Additional EU and UK Sanctions
On 29 September 2025, United Nations (“UN”) nuclear-related sanctions against Iran, which were suspended in 2015, were reimposed following action at the UN Security Council by France, Germany, and the United Kingdom. In parallel, the European Union (“EU”) and United Kingdom (“UK”) also reintroduced autonomous sanctions measures against Iran that
Continue Reading Reimposition of UN-Mandated Sanctions Against Iran and Additional EU and UK SanctionsU.S. Commerce Department Eases Export Control Restrictions for Syria
On September 2, 2025, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) published in the Federal Register a final rule titled Relaxing Export Controls for Syria (the “Syria Export Controls Rule”). The rule eases certain export controls applicable to Syria under the Export Administration Regulations (“EAR”) by adding
Continue Reading U.S. Commerce Department Eases Export Control Restrictions for SyriaTrump Administration Imposes Secondary Tariffs on India
On August 6, President Trump issued an Executive Order (“EO”) (“Addressing Threats to the United States by the Government of the Russian Federation”) invoking his authority under the International Emergency Economic Powers Act (“IEEPA”) to impose a tariff of 25% on most products imported from India, effective August 27, in
Continue Reading Trump Administration Imposes Secondary Tariffs on IndiaNew U.S. and UK Sanctions, Including Related to Russia’s Energy Sector
On January 10, 2025, the U.S. Department of the Treasury and U.S. Department of State intensified sanctions against Russia with new measures targeting Russia’s energy sector. According to the Treasury Department’s press release, these measures are intended “to fulfill the G7 commitment to reduce Russian revenues from energy” and “substantially increase the sanctions risks associated with the Russian oil trade.”
The new U.S. sanctions include a determination by the U.S. Department of the Treasury authorizing the imposition of property-blocking sanctions against any person who is determined by the Treasury Secretary or Secretary of State (in consultation with one another) to operate or have operated in the Russian energy sector, and a determination issued by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) prohibiting—effective February 27, 2025—the provision of “petroleum services” from the United States or by a U.S. person to any person located in Russia. In addition, OFAC and the U.S. Department of State collectively designated for property-blocking sanctions more than 400 individuals, entities, and vessels from various countries involved in Russia’s energy sector, including two of Russia’s most significant oil producers and exporters—Public Joint Stock Company Gazprom Neft (“Gazprom Neft”) and Surgutneftegas, along with more than two dozen of their subsidiaries. The designations included more than 180 vessels, many of which are part of Russia’s “shadow fleet” of vessels involved in the trade of Russian oil, as well as several Russian energy executives, oil traders, oilfield service providers, and financial and insurance entities associated with Russia’s energy sector. The designations also covered two active Russian liquefied natural gas (“LNG”) projects and a Russian oil project.
On January 15, 2025, the U.S. Department of the Treasury and U.S. Department of State designated or re-designated under additional sanctions authority nearly 250 individuals and entities for property-blocking sanctions, including actors based in China.
OFAC also issued multiple general licenses related to the above designations, including a general license authorizing until February 27, 2025, transactions ordinarily incident and necessary to the wind down of transactions involving Gazprom Neft and Surgutneftegas, their designated subsidiaries, and entities that they own 50 percent or more, directly or indirectly, individually or in the aggregate, subject to certain conditions. In addition, OFAC revoked a general license that had authorized transactions with certain vessels subject to U.S. property-blocking sanctions due to their ownership, and amended two existing general licenses. One of these amended general licenses, General License 8L (which supersedes General License 8K), significantly narrows the scope of permissible energy transactions involving certain blocked financial institutions to include only wind-down transactions until March 12, 2025.Continue Reading New U.S. and UK Sanctions, Including Related to Russia’s Energy Sector
U.S. Government Issues New U.S. Sanctions and Export Controls Targeting Russia and Belarus for Continued Aggression Against Ukraine; Update on European Sanctions Developments
June 18, 2024, Covington Alert
On June 12, 2024, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) and the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) issued additional measures to counter Russia’s continued aggression in Ukraine. The measures, announced in advance of the G7 summit in Italy last week, are intended to “continue to drive up costs for the Russian war machine.”
The actions taken by OFAC and BIS include new prohibitions on providing certain information technology- and software-related services to persons located in Russia, establishing additional sanctions designed to target the Russian financial infrastructure, strengthening secondary sanctions that can be applied to non-U.S. persons (including in particular non-U.S. financial institutions), and expanding export controls restrictions on items destined for Russia and Belarus (including with respect to certain types of software). Along with the new rules, OFAC designated for property-blocking sanctions more than 300 individuals and entities (including parties identified for sanctions by the U.S. State Department), while BIS used its authority to make additions to the Entity List, issue Temporary Denial Orders, and notify U.S. distributors of additional restrictions on shipments to parties known to be supplying items to Russia. Significantly, BIS altered its Entity List rules to permit certain address-only designations to the Entity List and, among other designations, added to the Entity List eight addresses in Hong Kong with a high diversion risk. Exports, reexports, or transfers of certain items subject to the Export Administration Regulations (“EAR”) to purchasers, intermediate or ultimate consignees, and end users who use those addresses generally will require authorization from BIS.
Separately, on June 13, 2024, the UK Government imposed a new round of asset-freezing sanctions on a number of notable Russian entities. The European Union is also considering a 14th package of sanctions measures relating to Russia, although as of this writing the EU has not yet enacted the new package.
New U.S. Sanctions
Prohibition on Certain Information Technology and Software Services
As part of the joint actions, OFAC issued a determination pursuant to the authority of Executive Order 14071 (the “IT and Software Services Determination”) that prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of (i) information technology (“IT”) consultancy and design services, and (ii) IT support services and cloud-based services for enterprise management software and design and manufacturing software (collectively, “Covered Software”) to any person located in the Russian Federation, unless licensed or otherwise authorized by OFAC. The IT and Software Services Determination is effective beginning at 12:01 eastern daylight time on September 12, 2024. “U.S. persons” include U.S. legal entities and their non-U.S. branches; U.S. citizens and lawful permanent residents, no matter where located or employed; and persons present in the United States.Continue Reading U.S. Government Issues New U.S. Sanctions and Export Controls Targeting Russia and Belarus for Continued Aggression Against Ukraine; Update on European Sanctions Developments