On November 21, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a determination (the Crude Oil Determination) pursuant to sections 1(a)(ii), 1(b), and 5 of Executive Order 14071 of April 6, 2022 (E.O. 14071, “Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression”), that certain “Covered Services” are subject to the prohibitions of E.O. 14071.

In recent weeks, U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued several general licenses that provide limited exceptions to certain activities that have been prohibited under various Executive Orders (E.O.s).

The White House recently announced that President Biden will meet with Chinese President Xi Jinping on Monday, November 14, 2022, in Bali, Indonesia, on the sidelines of the G20 Summit. Although the White House did not announce a specific agenda for the meeting, the battle over the future of microchip manufacturing will certainly hang over this first face-to-face meeting between Presidents Biden and Xi Jinping.

On October 31, Carlyle Aviation Partners LLC and Carlyle Aviation Partners Ltd. filed a complaint against a group of insurance companies and re-insurers in Florida state court alleging that the insurers failed to pay out for losses stemming from the seizure of their airplanes in Russia, following the start of the conflict in Ukraine. While the case is in its infancy, it is anticipated that a key issue will turn on the interpretation of the policy language and likely on whether this situation is subject to any exclusions.

Virtual currency mixers blend different streams of cryptocurrency to provide privacy about the source of funds that are being transferred through the financial system. While not illegal, currency mixers are widely viewed as a mechanism used to facilitate money laundering. The U.S. Department of the Treasury is cracking down on these virtual currency mixers.

On Friday, October 7, 2022, the Russian government moved forward by presidential decree to disenfranchise the owners of the Sakhalin-1 energy project, including the foreign nationals of several countries that the Russian government designated as “unfriendly countries.” Russia has applied the “unfriendly country” designation to any country, including the United States, that has joined in international sanctions against Russia.

Employers beware! The Occupational Safety and Health Administration (OSHA) is significantly expanding its “Severe Violator Enforcement Program” (SVEP). Employers that are placed into the program by OSHA will be significantly scrutinized, with the potential for very damaging information about their failure to maintain a safe workplace being made public for customers, partners, and vendors to see.