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New General License Authorizes Transactions with Sudan

Effective January 17, 2017, a new general license authorizes a broad range of activities previously prohibited under the Sudanese Sanctions Regulations (SSR), including most transactions with individuals and entities in Sudan...more

1/18/2017  /  BIS , ECCNs , General Licenses , OFAC , Sanctions , SDN List , Sudan , TSRA

New OFAC Guidance Offers Clarity on Operations Involving Iran

On December 15, 2016, the Office of Foreign Assets Control (OFAC) provided updated guidance on what companies can expect in the event of the “snapback” of sanctions under the Joint Comprehensive Plan of Action (JCPOA). ...more

International Trade in the Trump Era — Issues to Watch

Donald Trump’s victory in the 2016 Presidential election put the Republican Party in charge of the White House and Congress for the first time in a decade. President-elect Trump ran as an anti-establishment candidate who...more

U.S. Government Continues to Create New Opportunities for Trade with Cuba

Both the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have announced new amendments to the Cuban Assets Control Regulations (CACR) and Export...more

U.S. Announces End of Myanmar Sanctions – What Will Go and What Remains?

On September 15, 2016, President Obama announced that U.S. economic sanctions on Myanmar (also known as Burma) would end, but the announcement left many questions as to what would change and what sanctions might remain. On...more

OFAC Authorizes Temporary Sojourn of US-Controlled Aircraft to Iran

Today, OFAC issued new General License J (“GL J”) authorizing non-U.S. persons to reexport certain “Eligible Aircraft” to Iran. Importantly, GL J only applies to temporary sojourns, meaning that any sales or leases (including...more

8/1/2016  /  ECCNs , OFAC , Sanctions , SDN List , USML

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

Additional Steps to Ease U.S. Sanctions and Export Controls for Cuba prior to Obama Visit

In advance of President Obama’s highly publicized trip to Cuba, the Administration took additional steps to ease restrictions on trade and travel with Cuba. These changes to the Cuban Assets Control Regulations (CACR) and...more

Iran Sanctions Changes: Impact on the Aviation Sector

With “Implementation Day” came the lifting of certain key U.S. and EU sanctions on the civil aviation industry. However, many prohibitions still remain, and licensing requirements may attach to U.S. persons or non-U.S....more

Proposed Change to Export Controls Would Allow Use of the Cloud for Encrypted Data

On June 3, 2015 the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published proposed regulations which would change the definition of the...more

Framework for Nuclear Agreement with Iran Announced—But Still a Long Way to Go

On April 2, 2015 representatives of the United States, Britain, France, Germany, China and Russia (collectively, the “P5+1” countries) announced that they had agreed with the Islamic Republic of Iran on the Parameters for a...more

4/27/2015  /  Iran , Nuclear Power , P5+1 Nations , Sanctions

A New U.S. Course for Cuba Relations: What Does It Mean for Business?

President Obama made an unexpected announcement this week signaling a “new course” for Cuba after more than fifty years of comprehensive U.S. sanctions. Reestablishing diplomatic relations is a major change. In terms of...more

U.S. and EU Extend Temporary Iran Sanctions Relief a Second Time

The temporary and limited changes to U.S. and European Union (“EU”) sanctions policy for Iran, as agreed under the interim nuclear deal reached by Iran and the P5 + 1 countries, have been extended until June 30, 2015. Most...more

U.S. Steps Up Sanctions and Export Controls Against Russia’s Defense Industry

The United States recently expanded sanctions and export controls against the Russian defense sector. These designations and export control steps have implications for defense contractors, parts suppliers and brokers....more

Further European Union Sanctions Target Russia, Whilst Russia Retaliates

The United States, European Union and Canada each took steps recently to expand sanctions against Russia, including the targeting of major defense companies and the addition of export controls. These designations and export...more

8/11/2014  /  EU , Russia , Sanctions

Western Sanctions Expand as Tension in Ukraine Continues

The United States, Canada and the European Union have designated a number of additional officials and companies as the unrest continues in eastern Ukraine. The United States also imposed sanctions on the head of Russian...more

U.S. and UK Take Modest Steps to Restrict Exports to Russia

The Obama Administration has threatened to impose additional sanctions on Russia in response to the Ukraine crisis but so far has only blocked the assets of 32 individuals and one bank. Additionally, with little fanfare, the...more

4/2/2014  /  Exports , Foreign Policy , Russia , Sanctions , UK

Ukraine/Russia Sanctions Escalate

Sanctions escalated at a rapid pace last week as western powers responded to the crisis in Ukraine and Russian’s annexation of Crimea. The United States, European Union (EU), Canada and Australia have implemented sanctions....more

3/26/2014  /  Foreign Policy , Russia , Sanctions , Ukraine

New Ukraine Sanctions Announced – U.S., EU and Canada Take Action

In response to political developments in the Ukraine and Russian military action in Crimea, the United States and European Union (EU) announced new sanctions on March 6, 2014. Canada issued its sanctions on March 5, 2014. The...more

3/11/2014  /  Canada , EU , Foreign Policy , Ukraine

U.S. Ex-Im Bank Opens for Business in Burma/Myanmar

The U.S. Government has taken another important step in helping to reintegrate Myanmar (referred to as Burma for official purposes) into the global economy. On February 6, 2014, the Export-Import Bank of the United States...more

2/21/2014  /  Banks , Exports , Foreign Policy , Trade Policy

United States Implements Temporary Changes to Iran Sanctions under Interim Agreement

On January 20, 2014, the U.S. Treasury and State Departments took steps to implement temporary and limited changes to U.S. sanctions policy for Iran as agreed under the interim nuclear deal reached by Iran and the P5 + 1...more

Interim Deal on Iran Sanctions Policy Involves Limited Changes

Despite some confusing media reports, the interim nuclear deal reached by Iran and the P5 + 1 on November 24, 2013 would change very little in U.S. and multilateral sanctions policy. These limited changes are still pending...more

State Department Publishes Interim Final Rule to Clarify Defense-Broker Requirements

Section 38(f) of the Arms Export Control Act requires the registration of brokers of defense articles and defense services, pursuant to regulations currently published in Part 129 of the International Traffic in Arms...more

United States Issues Final Investment Reporting Requirements for Burma/Myanmar

On May 23, 2012, the U.S. State Department issued final “Responsible Investment Reporting Requirements” for Burma (also known as Myanmar). The long-awaited final rule confirms that U.S. persons will be required to submit: (a)...more

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