Miriam Gonzalez

Miriam Gonzalez

Dechert LLP

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US Commerce and Treasury Departments Further Ease Restrictions Against Cuba

The U.S. Commerce and Treasury Departments announced on January 26, 2016, actions to ease certain restrictions on transactions involving Cuba. The new actions do not significantly expand the types of activities in which U.S....more

1/27/2016 - Air Carriers Corporate Counsel Cuba Embargo Export Controls Financing Sanctions Travel Restrictions

Iran Sanctions: What is Prohibited or Licensable for EU Businesses?

Despite the easing of sanctions on Iran on 16 January under the Joint Comprehensive Programme of Action (JCPOA), some prohibitions and licensing requirements continue to apply to EU businesses. These are summarised below,...more

1/19/2016 - Dual Use Goods EU Exports Imports Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Licenses Military End Use Military Goods Nuclear Power Procurement Guidelines UN Security Council

Implementation Day: Iran Sanctions Eased Today

On Saturday, 16 January 2016, the International Atomic Energy Association (IAEA) submitted a report to the United Nations Security Council (UNSC) certifying that Iran has satisfied its obligations under the Joint...more

1/18/2016 - Implementation Day International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) SDN List Subsidiaries UN Security Council

Iran Sanctions: Early Easing of Sanctions Increasingly Possible

Public officials from the United States increasingly are making public statements regarding the likelihood that “Implementation Day” – the day on which many US and EU sanctions against Iran will be eased – will arrive in the...more

1/6/2016 - EU Implementation Day International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power OFAC UK

EU Sanctions: Commercial and Contract Risks

Sanctions programmes are established and developed as a political response to international relations developments; yet they impose significant obligations on commercial entities in terms of compliance. They may interfere...more

12/18/2015 - Affirmative Defenses Commercial Contracts Contract Drafting Contract Terms Economic Sanctions EU Force Majeure Clause

Reforms in the UK Export Control Organisation (ECO)

The ECO is making a combination of reforms, intended to improve its service in support of responsible defence and security exports while at the same time ensuring that the objectives of strategic trade controls to protect...more

12/1/2015 - Dual Use Goods Export Control Organisation (ECO) Export Controls License Agreements National Security Tariff Classifications UK

Modern Slavery Act Guidance. Are you a supplier of goods or services in the UK with a turnover above £36m? If you are, this...

The UK Government has published guidance1 on the transparency in supply chains provision of the Modern Slavery Act. Starting with those with a year-end of 31 March 2016, all organisations with a turnover above £36m will be...more

11/5/2015 - Annual Statements Audits Filing Requirements Franchisors Human Trafficking Modern Slavery Act Parent Corporation Partnerships Publicly-Traded Companies Reporting Requirements Risk Assessment Services Subsidiaries Supply Chain UK

EU Control List Update

The European Commission is revising the list of dual use items subject to EU export, transit and brokering controls. This briefing summarises the main new and deleted entries, primarily concerning machine tools, avionics...more

11/4/2015 - Aircraft Equipment Dual Use Goods EU European Commission Export Controls Exports Software Technology

Adoption Day in Iran Sanctions Deal: US and EU Give Clarification, But No Lifting of Sanctions Yet

The United States and European Union took preparatory steps on 18 October 2015 to begin fulfilling their commitments to suspend certain sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”)...more

10/22/2015 - Adoption Day Amending Regulation EU Financial Transactions Implementation Day Insurance Litigation International Atomic Energy Agency Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Metals Military Goods Nuclear Power OFAC Oil & Gas SDN List Shipping UN Security Council

U.S. Government Takes Steps to Further Ease Restrictions on Cuba

U.S. Commerce and Treasury Department measures intended to further ease existing export and sanctions restrictions regarding Cuba took effect on September 21, 2015. These amendments to the Cuban Assets Control Regulations...more

9/28/2015 - Cuba Cuban Assets Control Regulations (CACR) Export Administration Regulations Export Controls Internet Telecommunications Trade Restrictions U.S. Commerce Department U.S. Treasury

Iran Deal “Clears” Congress, But No Sanctions Relief Yet

On September 10, 2015, Senate Democrats in the U.S. Congress blocked a vote on a widely anticipated resolution to reject the Joint Comprehensive Plan of Action (“JCPOA”) regarding Iran’s nuclear program. On September 11, the...more

9/14/2015 - Adoption Day Asset Freeze EU Implementation Day Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons Political Parties UN Security Council United Nations

EU-Vietnam Trade Deal

The EU and Vietnam have concluded the substantive elements of a Free Trade Agreement (FTA), widely-hailed as one of the most ambitious and comprehensive such agreements that the EU has concluded with a developing country....more

8/28/2015 - ASEAN Funds Customs Duties EU Exports Free Trade Agreement Imports Origin Public Contracts Tariffs Vietnam

EU sanctions on Iran: Technical Amendments

The European Council has adopted two technical amendments to the EU’s sanctions on Iran. While related to the implementation of the Joint Comprehensive Plan of Action (JCPOA) agreed with Iran on 14 July, their effect is...more

8/6/2015 - EU Implementation Day International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons UN Security Council

The UK Modern Slavery Act 2015 (“the Act”) enters into force today. If you are a supplier of goods or services with a turnover of...

Annual Statements - The Act requires commercial organisations to publish an annual slavery and human trafficking statement. This must set out the steps that the organisation has taken in that financial year to ensure...more

8/5/2015 - Human Trafficking Modern Slavery Act Reporting Requirements Sale of Goods Act (SOGA) Suppliers UK

UK Export Licensing Trends

The Export Control Organisation (ECO) has released its latest set of data on export licensing. For the first time, this has been produced to be compliant with the UK Statistics Authority’s code of practice for official...more

7/24/2015 - Export Controls Exports Licensing Rules Military Goods UK

Nuclear Agreement with Iran Announced: Significant Easing of Iran Sanctions in Sight, but Only Outside of the United States

Iran and the P5+1 countries (United States, Russia, China, United Kingdom, France and Germany) on 14 July 2015 announced their agreement on a comprehensive plan under which certain international sanctions against Iran will be...more

7/15/2015 - International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) Nuclear Power Nuclear Weapons P5+1 Nations United Nations

Russia and Ukraine Sanctions - One Year On

The spring and summer of 2014 saw the United States and European Union impose a range of sanctions relating to Ukraine and Russia in response to the series of events leading to the fall of the Yanukovyich government in...more

6/29/2015 - Russia Sanctions Ukraine Ukraine Freedom Support Act

Revision of UK Military List of Controlled Items

The list of military goods, software and technology that are subject to export controls has been revised on 24 March 2015. The changes have been made through the Export Control (Amendment) Order 2015 which replaces Schedule 2...more

4/3/2015 - Criminal Prosecution Export Controls Exports Licenses Military Goods Penalties Software Technology UK

U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

3/30/2015 - Civil Monetary Penalty Compliance Criminal Penalties DOJ Enforcement Actions Guilty Pleas International Emergency Economic Powers Act Iran Sanctions OFAC PayPal Sanctions Schlumberger Settlement Sudan

US and Cuba Seek to Normalize Relations; US to Ease Certain Restrictions

President Obama announced on December 17, 2014 that the United States and Cuba will open talks seeking to restore full diplomatic relations, and that the United States will be taking a number of steps to ease restrictions in...more

12/18/2014 - Barack Obama Cuba Foreign Relations

New Law Significantly Expands Legal Basis for US Sanctions Against Russia

On 16 December 2014, President Obama announced that he will sign the Ukraine Freedom Support Act of 2014 (hereinafter the “Act”) into law. As discussed in our update dated 12 December 2014, the Act represents a potentially...more

12/18/2014 - Banking Sector Defense Sector Energy Sector FFI New Legislation OFAC Russia Sanctions Ukraine

US Clarifies Sanctions Provisions and US Senate Passes a Bill to Codify and Expand Sanctions

As noted in previous updates, the United States and European Union continue to impose sanctions against Ukrainian and Russian individuals and entities as a result of the turmoil in Ukraine. On 11 December 2014, the US Senate...more

12/14/2014 - Banking Sector Defense Sector Energy Sector OFAC Oil & Gas Russia Sanctions SDN List SSI List Ukraine

Amendments to EU Sanctions against Russia

The EU adopted amendments to the current EU sanctions against Russia on 4 December 2014. These amendments are implemented via Council Regulation (EU) No 833/2014 (as amended) (“Regulation 833/2014”). They are intended to both...more

12/10/2014 - Banking Sector Defense Sector Energy Sector EU Export Controls Exports New Amendments Oil & Gas Russia Sanctions

EU Imposes Further Sanctions on Ukrainian Separatists

On 29 November 2014, the European Union (EU) published measures targeting additional individuals and organisations to be added to the scope of EU sanctions measures against Russia. These measures widen the EU sanctions in...more

12/2/2014 - Asset Freeze EU Russia Sanctions SDN List Ukraine

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