Industrial Policy & Trade Monitor· 2667 actions· ✨ 89 recent

Switzerland's State Secretariat for Economic Affairs (SECO) and the US Treasury Office of Foreign Assets Control (OFAC) signed a Memorandum of Understanding on 9 May 2025 (jointly published 16 May 2025) establishing a framework for information-sharing, coordinated investigations, designated points of contact, regular bilateral meetings, joint training, and exchange of technical expertise on sanctions enforcement. The MoU is not legally binding and neither side is obliged to share information, but it formalises an enforcement-cooperation channel that previously operated only ad-hoc. It is the first sanctions-enforcement MoU Switzerland has concluded with a third country (the US has a comparable arrangement with the UK's OFSI), and SECO has indicated more such MoUs will follow.

The Office of Foreign Assets Control (OFAC) issued a final rule on 19 December 2024 amending 32 parts of 31 CFR chapter V to modernize the general licenses authorizing payments for legal services from funds originating outside the United States. The rule replaces the annual reporting requirement that had applied to such payments with a 10-year recordkeeping requirement, aligning the legal-services general licenses with the new 10-year statute of limitations for IEEPA/TWEA violations and OFAC's parallel 5→10-year recordkeeping extension (31 CFR 501). The rule also standardises legal-services general-license language across programs — removing legacy letter-of-engagement prerequisites in certain parts (e.g., 31 CFR 594, 597), updating 31 CFR 549 (Lebanon) and 31 CFR 576 (Iraq Stabilization and Insurgency) to remove the requirement that payments for authorised legal services be separately specifically licensed, and harmonising the 31 CFR 591 (Venezuela-related) authorisation language. The rule was effective 19 December 2024 with an applicability date of 12 March 2025.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 84472–84474, FR Doc 2024-24524) three general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 3A, GL 4, and GL 5. All three were originally issued on 18 June 2024 concurrent with OFAC's expansion of Republika Srpska / Dodik-network designations; the 23 October 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 3A (which superseded GL 3 of 16 November 2023) authorises transactions involving certain WBSR-blocked entities that are ordinarily incident and necessary to the exportation or re-exportation of agricultural commodities, medicine, medical devices, replacement parts and components, software updates, or activities involving medical prevention, diagnosis, treatment, or clinical trials. GL 4 authorises wind-down transactions with entities blocked on 18 June 2024 through a defined cutoff. GL 5 authorises transactions ordinarily incident and necessary to the manufacture, distribution, operation, installation, or maintenance/repair of drinking-water pumps manufactured or distributed by the WBSR-blocked Bosnian Serb entity Kaldera Company EL PGP d.o.o. (and 50%-or-more-owned subsidiaries), preserving municipal water supply continuity.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published in the Federal Register (89 FR 16400, FR Doc 2024-04856) two general licenses issued under the Western Balkans Stabilization Regulations (31 CFR Part 588): GL 2 and GL 3. Both were originally issued on 16 November 2023 concurrent with OFAC's initial round of Republika Srpska / Dodik-network designations; the 7 March 2024 Federal Register notice formalises them per the Administrative Procedure Act notice requirements. GL 2 authorises wind-down transactions with newly blocked WBSR entities through 15 March 2024. GL 3 authorises exports and re-exports of agricultural commodities, medicine, medical devices, replacement parts, and services for medical prevention and treatment to WBSR-blocked persons; GL 3 was subsequently superseded by GL 3A on 18 June 2024.

The U.S. Treasury's Office of Foreign Assets Control (OFAC) published a final rule in the Federal Register (89 FR 15769, FR Doc 2024-04500) renaming the Darfur Sanctions Regulations (31 CFR Part 546) to the Sudan Stabilization Sanctions Regulations and amending them to implement Executive Order 14098 of May 4, 2023. E.O. 14098 broadened US sanctions authority beyond the Darfur-specific frame to cover all persons destabilising Sudan and undermining democratic transition, responding to the SAF–RSF armed conflict that erupted in April 2023. The rule adds new general licenses covering legal-service payments (§ 546.508), African Union transactions (§ 546.511), and agricultural/medical exports (§ 546.513), and introduces an interpretative provision clarifying that entities are not automatically blocked solely because a blocked individual holds a leadership position.

OFAC adopted a final rule (FR Doc 2023-08870) correcting a typographical error in the Iranian Transactions and Sanctions Regulations (31 CFR § 560.528, "insure" → "ensure") and two cross-reference errors in the Western Balkans Stabilization Regulations (31 CFR §§ 588.307 and 588.405). Most substantively, the rule properly incorporates the nongovernmental organizations general license (GL 1) into the WBSR at § 588.512 — that GL was originally issued as a standalone web action on 21 December 2022 but failed to codify due to an error in the amendatory instructions. No new prohibitions or designations are created; the rule formalises existing authorisations and corrects drafting errors.