75% domestic requirement takes effect in 2029 On March 7, the Federal Acquisition Regulatory (FAR) Council issued a final rule changing the “Buy American” requirements for federal contractors. The final rule is very similar to the proposed rule published in July 2021 and it materially changes the regulations at FAR Part 25, which implements the … Continue Reading
Consistent with the Biden Administration’s keen focus on improving the nation’s cybersecurity, as articulated in Executive Order 14028 and discussed in greater detail here, the Department of Justice (DOJ) formally announced the launch of its new Civil Cyber-Fraud Initiative (Initiative) on October 6, 2021. The Initiative will “combine the department’s expertise in civil fraud enforcement, … Continue Reading
On Thursday March 21, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) updated the advisory document it published on February 23 regarding North Korea’s illicit shipping practices. The updated guidance provides further information about North Korea’s deceptive shipping practices aimed at evading international sanctions and provides a list of ‘red … Continue Reading
On Monday January 28, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed strong sanctions on Petróleos de Venezuela, S.A. (PdVSA), a major Venezuelan state-owned oil and natural gas company. The U.S. is now prohibited from engaging in transactions with the company, and all property and interests in property of PdVSA that are … Continue Reading
On January 27, 2019, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) removed UC Rusal plc (Rusal), En+ Group plc (En+), and JSC EuroSibEnergo (ESE) from the Specially Designated Nationals (SDN) List, reducing the number of Russian entities sanctioned by the United States. Our Sanctions Team explores the implications in our recent client … Continue Reading
On November 5, the United States reimposed the final tranche of sanctions on Iran, which had been lifted pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) in 2016. The vast majority of these sanctions are “secondary sanctions,” being those which target non-U.S. persons and companies even where there is no U.S. nexus (e.g. the … Continue Reading
On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. … Continue Reading
In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous … Continue Reading
President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (JCPOA) on 8 May 2018. In conjunction with that announcement, the president issued a National Security Presidential Memorandum directing the re-imposition of certain secondary sanctions, being those that apply to non-U.S. persons even where there is no U.S. nexus. … Continue Reading
President Trump issued a new executive order (the EO) on September 21st that greatly expands the U.S. sanctions against North Korea, particularly secondary sanctions. Secondary sanctions apply to non-U.S. individuals and corporations and are imposed by the U.S. Secretary of the Treasury, in consultation with the U.S. Secretary of State. The EO establishes the following: … Continue Reading
On February 2nd the Office of Foreign Assets Control (“OFAC”) imposed new sanctions on 13 individuals and 12 entities that were believed to be “involved in procuring technology and/or materials to support Iran’s ballistic missile program, as well as for acting for or on behalf of, or providing support to, Iran’s Islamic Revolutionary Guard Corps-Qods … Continue Reading
Before President Obama’s exit from The White House, he removed most of the sanctions in place against Sudan. While President Trump and the Secretary of State ultimately have the final decision, it is believed they were consulted by the Obama administration about these changes. The relaxed Sudan sanctions will allow U.S. persons to engage in … Continue Reading
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added five new Frequently Asked Questions (FAQs) on 6 January 2017. The new FAQs were in reference to a general license that OFAC issued on October of 2016. The license considerably lessened the ‘180-day’ rule – a restriction that makes foreign-flag vessels wait at least … Continue Reading
As a direct result of nuclear and ballistic weapons tests conducted by the Democratic Peoples’ Republic of North Korea earlier this year, the United Nations, the European Union and the United States imposed increased sanctions against the country. These new restrictions affect various industries, including minerals, energy, shipping, banking, finance, and aviation. In keeping with … Continue Reading
Reed Smith has been closely monitoring developments in U.S.-Cuba relations. With President Obama’s historic visit to Cuba in the books, we invite you to take a closer look at some recent amendments that were made to Cuban Assets Control Regulations (CACR) and Export Administration Regulations (EAR). These changes provide significant benefits in the travel, shipping, … Continue Reading
In keeping with the continued efforts of the White House to re-establish diplomatic relations with Cuba, the United States recently modified its stance on travel to Cuba and eased certain export restrictions. Reed Smith’s International Trade & National Security team has authored a client alert that summarizes the policy amendments, and explains the implications for … Continue Reading
18 October 2015, marked ‘Adoption Day’ for the Joint Comprehensive Plan of Action (JCPOA). The JCPOA was agreed upon 90 days earlier, between the United States, Russia, China, the United Kingdom, France, and Germany, together with Iran. While the latest measures taken by the EU, the United States and Iran make the necessary legal preparations … Continue Reading
In keeping with the Obama Administration’s efforts to normalize relations with Cuba, the U.S. government is making further amendments to CACR and EAR. While the overall embargo is still in place, these amendments will lessen the degree of various restrictions. The effects will be seen in areas including travel, telecommunications and internet-based services, commercial and … Continue Reading
On 24 November 2013, the P5+1 countries (comprising the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, agreed the Joint Plan of Action (JPOA), which relaxed some of the sanctions imposed against Iran by the EU and U.S. The JPOA was intended to provide interim sanctions relief, while the parties worked … Continue Reading
In our alert of 8 July, we reported that the P5+1 and Iran had announced the extension of the Joint Plan of Action Relief Period (the JPOA Relief Period) to today, 10 July 2015. Negotiations with Iran continue. To allow more time for the parties involved to reach a long-term solution, the JPOA Relief Period … Continue Reading
Amid the often rancorous debate on the Trans Pacific Partnership and the Trade Promotion Authority enabling legislation, both the House and the Senate last week found a common ground in addressing legislation related to the international movement of goods and passed the Trade Preferences Extension Act of 2015 (The Act), reviving the Generalized System of … Continue Reading
On March 25, 2015, Schlumberger Oilfield Holdings, Ltd. (“SOHL”), a wholly owned subsidiary of Schlumberger Ltd., the world’s largest oil-field services company (collectively “Schlumberger”), agreed to plead guilty to criminal charges, enter into a plea agreement, and pay $232.7 million in penalties for willfully facilitating illegal transactions and engaging in trade with Iran and Sudan. … Continue Reading
On February 18, 2015 the Commerce Department’s Bureau of Industry and Security (“BIS”) and Treasury Department’s Office of Foreign Assets Control (“OFAC”) published changes to the Export Administration Regulation (“EAR”) and the Sudanese Sanctions Regulations (“SSR”) in order to advance the free flow of information and facilitate communications by the Sudanese people. OFAC’s changes are … Continue Reading
In response to recent cyber-attacks, President Obama signed an Executive Order January 2, 2015, imposing additional economic sanctions against the Democratic People’s Republic of Korea. The Executive Order authorizes the Treasury to apply sanctions against officials and entities associated with North Korea’s government and the ruling Workers’ Party of Korea. Click here for the issued … Continue Reading
