Global Trade Sanctions Developments: Weekly Update for July 6-10

US – BIS – UAE Export-Control Easing

On July 10, BIS announced a significant upgrade to the UAE’s treatment under the EAR. The UAE was removed from Country Groups D:3 and D:4 and reclassified into Country Group A:5. BIS described the change as allowing the UAE Government and approved commercial entities to receive certain items license-free under License Exception STA, including Commerce-controlled military items, certain commercial satellites and spacecraft, and dual-use items useful in sectors such as oil and gas, desalination, and civil nuclear activity. BIS also stated that the UAE Government and certain companies would be approved to receive advanced computing items license-free, including AI chips and servers.

The implementing rule was filed for public inspection on July 10 and scheduled for Federal Register publication on July 14, under the title “Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations.” Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations

US – OFAC – Russia GL 13R and FAQs

On July 8, 2026, OFAC issued Russia-related General License 13R, replacing and superseding General License 13Q and extending the existing authorization for certain routine administrative transactions involving Russia through 12:01 a.m. EDT on October 9, 2026. The change is narrow but practically important for companies that continue to maintain a lawful, ring-fenced presence in Russia: GL 13R continues to authorize U.S. persons and entities owned or controlled by U.S. persons to engage in transactions otherwise prohibited by Directive 4 under Executive Order 14024, but only where those transactions are ordinarily incident and necessary to day-to-day operations in Russia. Covered activity may include the payment of taxes, fees, import duties, and similar governmental charges, as well as the purchase or receipt of permits, licenses, registrations, certifications, and tax refunds. OFAC also updated related FAQs to conform to GL 13R and reaffirmed that the authorization does not cover Russia “exit tax” payments associated with divestment, which are not considered ordinary day-to-day operating expenses and require a specific OFAC license. Accordingly, GL 13R should be viewed as a maintenance authorization, not a broader relaxation of Russia sanctions: it preserves a pathway for routine legal-entity, tax, customs, and regulatory compliance activity, but does not authorize new investment, prohibited services, dealings with blocked persons, prohibited exports, divestment-related exit payments, or other non-routine Russia transactions. OFAC recent actions

Disclaimer: this summary is provided for informational and educational purposes only and does not constitute legal advice. It is intended to offer a general overview of recent regulatory developments based on publicly available information. Readers should not act upon this information without seeking specific legal or compliance advice tailored to their particular circumstances. No attorney-client relationship is created by this summary, and the author assumes no responsibility or liability for any actions taken or not taken based on its contents. 

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