This post was also written by Alexandra E. Allan and Tom C. Evans This alert follows our previous alerts on the Russia/Ukraine sanctions. U.S. Passes New Sanctions Authorizing Statute – Sends Russia Frigid End of Year Message President Obama: U.S. will “review and calibrate” sanctions in response to Russia’s actions On December 18, 2014, President Obama signed into … Continue Reading
On December 17, President Obama announced that he will take steps to normalize relations with Cuba, prompting questions about what this means for an island nation that has existed under a Cold War-era embargo for more than 50 years. The announcement indicates a dramatic shift in U.S. foreign policy toward Cuba, affecting not only diplomatic … Continue Reading
This post was also written by Alexandra E. Allan, Laith Najjar, Tom C. Evans On 24 November 2013, an agreement was reached between the E3+3 (also known as the P5+1, and which includes the United States, United Kingdom, Russia, China, France and Germany) and Iran. This agreement, known as the Joint Plan of Action (JPOA), was … Continue Reading
In January 2014, both the EU and U.S. brought into force measures which temporarily suspended and relaxed (for an initial period of six months) some of the sanctions in place against Iran. This reflected the Joint Plan of Action (JPOA) agreed to in November 2013 between Iran and the E3+3, also known as the P5+1, … Continue Reading
On September 16, 2014, the Court of Appeals for the Federal Circuit published its long-awaited decision in United States v. Trek Leather Inc., and its opinion may have created an unintended level of concern among compliance professionals and import departments. Trek Leather is an importer of men’s suits. Its business plan called for the importer … Continue Reading
As the United States and Russia continue to clash over Russia’s actions in the Ukraine, on September 12, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued additional sanctions further restricting designated Russian financial institutions’ access to capital markets, targeting Russian defense entities, and prohibiting exports to Russian entities that have been specifically … Continue Reading
On August 13, 2014, the Office of Foreign Assets Control (“OFAC”) revised its guidance on the status of entities owned by persons designated on the Specially Designated Nationals List (“SDN List”). Under the new guidance, OFAC will consider an entity to be blocked if it is 50 percent or more owned, directly or indirectly, in … Continue Reading
Effective August 6, 2014, the United States Department of Commerce’s Bureau of Industry and Security (“BIS”) issued new regulations, identified as the “Russian Industry Sector Sanctions,” restricting exports and other transfers of certain items subject to the Export Administration Regulations (“EAR”) that may benefit Russia’s energy sector. Newly added EAR section 746.5 imposes licensing requirements … Continue Reading
This Alert follows our previous alerts on the Russia/Ukraine sanctions available on our website. July continued to be a busy time as the Verkhovna Rada (the Ukrainian Parliament), the EU and the United States intensified their responses to the situation in the Crimea and the escalating situation in eastern Ukraine. The United States has hinted … Continue Reading
As a result of the ongoing Crimea conflict, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has issued new sanctions targeting Russian banks and energy companies. This week, OFAC issued a Ukraine-related Sectoral Sanctions Identifications List (“SSI List”) and Directives 1 and 2 pursuant to Executive Order 13662 (the “Directives”) that provide two … Continue Reading
On April 28, the U.S. Department of Commerce announced a new licensing policy restricting exports of “dual use” items that could contribute to Russia’s military capabilities. Effective immediately, the Commerce Department’s Bureau of Industry and Security (“BIS”) will deny new and pending export license applications to Russia or occupied Crimea of high-technology items that could … Continue Reading
On April 9th, the Bureau of Industry and Security (“BIS”) proposed a rule that would remove certain documentation requirements in connection with Export Administration Regulations (“EAR”) license applications. Export nerds are well aware that changing these requirements would go a long way toward streamlining the license application process (which is ridiculous and complicated). As the … Continue Reading
The Russian Federation and the United States continue to clash over the proposed annexation of Crimea from Ukraine, with the United States adding 20 Russian officials and related persons to its list of sanctioned persons. Some of the persons recently added to the United States’ SDN List were recently sanctioned by the EU, as we … Continue Reading
On March 19, the Office of Foreign Assets Control (“OFAC”) issued a general license under the Iranian Transactions and Sanctions Regulations that authorizes several specific forms of academic exchanges with Iran. The newly issued general license – General License G (the “License”) – authorizes qualifying U.S. colleges and universities to engage in certain transactions related … Continue Reading
U.S. persons traveling to Iran for business can now take heart, because they, as well as most laptops and smart phones, may do so without the need for a license. A recent amendment to the wordily-named “General License with Respect to Certain Services, Software, and Hardware Incident to Personal Communications” (formerly “General License D,” now … Continue Reading
Tensions continue to mount between the Russian and Ukrainian governments in the wake of a controversial referendum that threatens to expand the borders of the Russian Federation. The results of that Crimean plebiscite show that an estimated 97 percent of voters favor the Russian annexation of Crimea, but the peninsula’s ethnic Tartars boycotted the referendum. … Continue Reading
Speaking on Sunday’s talk-show circuit, Secretary of State John Kerry condemned Russia’s military intervention in the Crimea, accusing the Kremlin of invading the Ukraine and violating the UN Charter. The condemnation echoes calls from Capitol Hill to impose immediate sanctions against Russia, but Putin will likely persist despite such threats. In the past, Russia ignored … Continue Reading
When the U.S. State Department late last month announced the administrative debarment of a former senior export compliance officer from Honeywell International, Inc. (“Honeywell”), reports on and analyses of the event focused on the multiple allegations of what went wrong. This was with good reason: any time a significant case of export noncompliance comes to … Continue Reading
On November 23, 2013, the White House issued a Press Release (“the Announcement”) outlining the first of a two-step negotiation process between Iran and the United States, the United Kingdom, Germany, France, Russia, and China (the “P5+1”). The Announcement calls for the P5+1 countries to provide limited sanctions relief to Iran in exchange for Iran’s … Continue Reading
When your work involves export controls, it’s good to remember that reform – especially in the form of decontrol – seldom has an immediate impact. It’s been just over a year since the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) lifted its restrictions on the export and re-export of certain medicines and medical … Continue Reading
On October 10, 2013, the U.S. District Court for the District of Columbia issued an amended ruling dismissing Ralls Corporation’s (“Ralls”) challenge to a presidential order requiring divestiture of its interest in four companies engaged in developing wind farms near a Naval base in Oregon. After the deal concluded, Ralls – a Delaware corporation privately … Continue Reading
This post was also written by Gautam Bhattacharyya. In June 2013, Secretary of State John Kerry issued a statement announcing that Singaporean financial institutions would be temporarily exempt from U.S. sanctions under Section 1245 of the National Defense Authorization Act. Singapore, and eight other countries, qualified for the exceptions because they reduced their volume of … Continue Reading
As members of the United Nations prepared to descend upon Manhattan’s East Side, the U.S. government was moving to seize a building only 13 blocks away. On Monday, September 16, 2013, following a civil complaint originally filed in 2008 by the Manhattan U.S. Attorney’s Office, the U.S. District Court for the Southern District of New … Continue Reading
As part of the U.S. Government’s Export Control Reform Initiative, the Justice Department’s U.S. Munitions Import List (“USMIL”) has been “delinked” from the State Department’s U.S. Munitions List (“USML”). On April 22, 2013, the DOJ’s Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”) issued a final rule that distinguishes defense articles and services controlled by … Continue Reading
