Today the U.S. Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) to fully re-impose U.S. sanctions on Iran following a wind down period that expired yesterday, November 4, 2018. OFAC also issued new FAQs for foreign affiliates of U.S. companies and non-U.S. companies. Foreign affiliates … Continue Reading
It has always been a possibility that the United Kingdom would crash out of the European Union on 30 March 2019 but “no deal” preparation is now highly recommended by both sides. For organisations that export dual use items, the possibility of the UK becoming a “third country” vis-à-vis the EU without an exit agreement … Continue Reading
Yesterday the U.S. government announced that it would implement new sanctions against Russia mandated under the Chemical and Biological Weapons Act of 1991 (the CBW Act) following the apparent deployment of a chemical weapon on British soil by Russia. The first round of sanctions, which are expected to come into force on or around August … Continue Reading
A set of changes to the U.S. dual use export control rules makes exporting sensitive goods, software, and technology to India less burdensome. Over the last several years, India has joined three of the four major multilateral export control regimes – the Missile Technology Control Regime (MTCR), the Wassenaar Arrangement, and the Australia Group. In … Continue Reading
Tomorrow the United States will re-impose a set of secondary sanctions on Iran as the newly amended EU blocking statute comes into force. Following the U.S. withdrawal from the multilateral Iran nuclear deal (the Joint Comprehensive Plan of Action or JCPOA), the United States is set to re-impose a raft of secondary sanctions targeting Iran. … Continue Reading
Today the U.S. Department of Commerce lifted its denial order on Chinese telecommunications firm ZTE Corp., allowing THE U.S. and other companies to resume most business with ZTE. The Commerce Department imposed the denial order in April after ZTE made false statements to the Commerce Department in connection with an earlier settlement agreement regarding violations … Continue Reading
Yesterday the Office of Foreign Assets Control (OFAC) formally rescinded General License H, requiring foreign subsidiaries of U.S. companies to wind down remaining business related to Iran by 11:59 pm EST on November 4, 2018. After that date, foreign subsidiaries of U.S. companies and other owned or controlled entities will generally be prohibited from conducting … Continue Reading
On June 4, 2018, Russian President Vladimir Putin signed into law new counter-sanctions in response to U.S. sanctions imposed against Russia on April 6, 2018. Under the new law, Putin may, among other things, sever ties with unfriendly countries and ban trade of goods with those countries. The final version of the law stopped short … Continue Reading
Yesterday, the President issued a new Executive Order (E.O.) prohibiting certain financial transactions involving the Venezuelan government, including Petroleos de Venezuela, S.A. (PdVSA), the state-owned oil company. Under the new rules, persons subject to U.S. jurisdiction are prohibited from engaging in transactions related to: (i) the purchase of any debt owed to the Government of … Continue Reading
Today, the EC announced that it is moving forward with a package of measures to blunt the impact of renewed U.S. sanctions on Iran following the U.S. exit from the Joint Comprehensive Plan of Action (JCPOA). Included in those measures is the planned activation of the EU blocking statute, which would bar EU companies from … Continue Reading
On Tuesday President Trump announced that the United States will exit the multilateral Iran nuclear deal and fully re-impose sanctions on Iran. After the announcement, the Office of Foreign Assets Control (OFAC), the agency responsible for administering most U.S. sanctions, issued a statement and guidance on the re-imposition of U.S. sanctions. This announcement reflects a … Continue Reading
Penalties for violations of sanctions rules administered by the Office of Foreign Assets Control (OFAC) ticked up again yesterday. Most violations of OFAC’s rules now face statutory penalties of $295,141 or twice the value of the underlying transaction. Penalties for violations of OFAC’s narcotics trafficking regulations are now set at $1,466,485, with penalties for violations … Continue Reading
The President signed a new Executive Order today making it unlawful to engage in transactions involving digital currency issued by the Venezuelan government. The Executive Order makes official prior guidance from the Office of Foreign Assets Control (OFAC), which stated that dealings related to Venezuelan digital currency would likely be prohibited under existing sanctions. Last … Continue Reading
Yesterday, the U.S. Office of Foreign Assets Control (OFAC) blacklisted 14 new Russian individuals and the Internet Research Agency as Specially Designated Nationals (SDNs) for their role interfering with the 2016 U.S. presidential election. While limited in scope, the new designations are the first use of authority under the Countering America’s Adversaries Through Sanctions Act (CAATSA) … Continue Reading
The Office of Foreign Assets Control (OFAC)’s new North Korea Sanctions Regulations become effective today. In addition to making certain technical and conforming changes, the newly updated Part 510 incorporates recent changes to the sanctions program under Executive Orders (E.O.) 13687, 13722, and 13810, the North Korea Sanctions and Policy Enhancement Act of 2016, and … Continue Reading
Today the U.S. Office of Foreign Assets Control (OFAC) issued new sanctions targeting the shipping industry for dealings involving North Korea. The sanctions include the designation of 56 companies and vessels involved in conducting illegal trade with North Korea. OFAC also issued new guidance for the global shipping and finance industries, describing common methods used … Continue Reading
The United States imposed new sanctions against 21 Russian companies today by adding them to the Commerce Department’s Entity List. Among other restrictions, U.S. and non-U.S. companies are now prohibited from transferring any U.S.-origin items to the sanctioned Russian firms. The parties were added to OFAC’s SDN List last month.… Continue Reading
As required under Section 241 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), last night the U.S. government released a public, unclassified version of the much-anticipated “Kremlin Report.” The report was intended to ‘name and shame’ Russian political and business leaders, list their assets outside of Russia, provide an index of corruption with respect … Continue Reading
Under Section 231 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), the Trump administration was due to issue secondary sanctions on non-U.S. persons that conduct significant transactions with Russia’s defense and intelligence sectors. The Trump administration declined to issue those new sanctions, claiming that CAATSA was serving as an effective deterrent – discouraging non-U.S. … Continue Reading
Last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) blacklisted 21 individuals and nine entities for various reasons, including involvement in the ongoing conflict in eastern Ukraine, connections to the Crimea region (which is subject to a complete U.S. embargo), and links to the Russian government. Several of the newly … Continue Reading
In December last year, Venezuelan President Nicolas Maduro announced that Venezuela would launch a cryptocurrency called “Petro” in an effort to ease the country’s serious economic woes and avoid U.S. sanctions. Maduro said the government would issue 100 million Petros, with each Petro backed by one barrel of Venezuelan oil. So will U.S. companies finally … Continue Reading
Last week the President begrudgingly extended waivers continuing to lift U.S. “secondary sanctions” on Iran. But the President also insisted that he will not issue further extensions without a renegotiation of certain aspects of the joint nuclear deal with Iran (the Joint Comprehensive Plan of Action or JCPOA), throwing the future of the deal and … Continue Reading
On December 20, 2017, the President issued Executive Order 13818 implementing new sanctions against human rights abusers and persons involved in corruption pursuant to the Global Magnitsky Human Rights Accountability Act (Global Magnitsky Act). The Global Magnitsky Act allows the U.S. government to target persons and entities involved in gross human rights abuses – such … Continue Reading
Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But distributors can also create sanctions liability for companies, especially when foreign subsidiaries or others within the company are in on the … Continue Reading
