Reid Whitten

Reid Whitten

Sheppard Mullin Richter & Hampton LLP

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Those Three Little Words: OFAC’s Subtle Language Shift Could Create Sweeping Change on Iran Investment

Article Highlights: - Non-U.S. banks can do business with Iran and continue their relationships with U.S. banks. - Non-U.S. companies may use proceeds from Iran transactions more freely, including in the United...more

10/11/2016 - Banking Sector Banks Financial Institutions Foreign Financial Institutions (FFI) Foreign Investment Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC SDN List

Layover in Tehran: United States Authorizes Carriers to Land Civil Aircraft in Iran

On July 29, 2016, the U.S. Treasury Office of Foreign Assets Control (OFAC) cleared the runway for non-U.S. operators of civil aircraft to send flights into Iran. New “General License J” authorizes many Boeing, Airbus, and...more

8/18/2016 - Air Carriers Aircraft General Licenses Iran Iran Sanctions OFAC

The Morning After: Waking up to Brexit and Its Impact on Your Business

On the morning of June 24, 2016, we woke up to a headline that had been much discussed, but still added a jolt to many people’s morning coffee: Britain to Leave the European Union....more

6/27/2016 - Bargaining Power Bilateral Agreements Economic Sanctions EU Export Controls Member State Referendums Trade Agreements UK UK Brexit

Flying the Too-Friendly Skies? Europe Opens Routes for Sanctioned Iran Airline

On June 20, 2016, you will be able to take a non-stop flight from Tehran to Paris . . . but you probably shouldn’t. According to its website, the Iranian airline Mahan Air will add the City of Lights to the list of...more

6/10/2016 - Airlines EU France Iran Iran Sanctions OFAC Public Private Partnerships (P3s) SDN List State-Owned Enterprises

New Business Opportunities in Iran! Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for...

- Sanctions relief presents new business opportunities with Iran - Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies - The...more

4/21/2016 - Banking Sector Business Opportunities Financial Transactions Iran Iran Sanctions Non-US Entities

The Day of North Korea Sanctions: the UN Imposes the Toughest North Korea Sanctions Yet While OFAC and State Designate More North...

After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry,...more

3/4/2016 - Arms Embargo Asset Freeze Corporate Counsel Exports Imports North Korea Nuclear Weapons OFAC Sanctions SDN List UN Security Council Vessels WMD

EU-US Privacy Shield: Brace Yourself . . . or Maybe Not

On February 29, 2016, the European Commission and United States released the terms of the much-anticipated renewed framework for the transfer, sharing, and processing of European individuals’ data to the United States. The...more

3/4/2016 - Data Protection Authority EU EU-US Privacy Shield European Commission European Court of Justice (ECJ) FTC International Data Transfers Ombudsman Personal Data Schrems v Data Protection Commissioner Surveillance U.S. Commerce Department US-EU Safe Harbor Framework

US and EU Iran Sanctions Lifted: How to Proceed in the Aviation Sector?

On 16 January 2016, the United States and the EU lifted certain sanctions against Iran in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreed among Iran, China, France, Germany, the Russian Federation, the...more

1/21/2016 - Aircraft Aviation Industry EU Implementation Day International Atomic Energy Agency Iran Iran Sanctions Joint Comprehensive Plan of Action (JCPOA) OFAC SDN List

The Trans Pacific Partnership and the Auto Industry: Will Six Thousand Pages Pave the Way for Increased Exports?

The Open Road: Approaching the TPPan - Summarizing the behemoth 12-nation TPP agreement in a few-hundred word blog is a task beyond the reach of a practicing attorney . . . assuming he wants to continue practicing. In...more

11/13/2015 - Auto Manufacturers Automotive Industry Country of Origin Exports Tariff Classifications Trans-Pacific Partnership

Keep Your Frenemies Close: Proposed China Sanctions and the Price of Escalation

On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new...more

9/18/2015 - China Compliance Cyber Attacks Cyber Crimes Cyber Espionage Cybertheft Data Breach Foreign Corporations Hackers NSA Nuclear Power Obama Administration Sanctions Search Engines Source Code Visas

Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?

After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately,...more

7/19/2015 - EU Exports IFCA Iran Iran Sanctions Iran Threat Reduction and Syria Human Rights Act Joint Comprehensive Plan of Action (JCPOA) Manufacturers NDAA Non-US Entities Nuclear Power Nuclear Weapons

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

5/20/2015 - Alstom Bribery Chief Compliance Officers Compliance Corruption DOJ Government Investigations Plea Agreements Serious Fraud Office Suspensions & Debarments UK UK Bribery Act

The Broader Problem: European Bank Creates an Easy Catch for the Long Arm of U.S. Jurisdiction

On March 12, 2015, Commerzbank AG, Germany’s second largest bank and a global financial institution, agreed to pay $1.45 Billion (yes, with a “B”) in forfeitures and fines to the U.S. Government for violating U.S. sanctions...more

4/2/2015 - Commerzbank Corporate Fines DOJ Extraterritoriality Rules Forfeiture Iran Sanctions Jurisdiction Non-Judicial Settlement Agreements Sanctions Sudan

Read the Directions Carefully Before Playing: State Department Releases Military Drone Export Guidance

The United States has a responsibility, or so the State Department tells us, to ensure the sales and exports of Unmanned Aerial Systems (UAS) are consistent with U.S. national security interests, U.S. policy, and even U.S....more

3/6/2015

Change Your Entire Energy Export Policy Using This One Weird Trick! BIS “Clarifies” Short Supply Controls to Make Oil Exporting...

On December 30 the Commerce Department shifted the oil export landscape as it had existed for 40 years, with only a little administrative sleight-of-hand. ...more

1/16/2015 - BIS Export Controls Exports Guidance Update Oil & Gas U.S. Commerce Department

A New Latitude: Charting a Course for Cuba

Today President Barack Obama made a stunning speech announcing steps the United States will take to reduce U.S. sanctions against Cuba. The announcement followed the release of two U.S. citizens held by the Cuban government....more

12/18/2014 - Barack Obama Cuba Foreign Relations

Military Electronics Export Reform: Let the Chips Fall Where They May

Every time there is a new round of reforms under the President’s Export Control Reform initiative, we hear the same advice: - Controls on certain items are eliminated or reduced (which creates new opportunities for...more

12/8/2014

Bulletin: Commerce Department Statistics on the First Year of Export Control Reform

Here is a summary of export data for the first year after the initial implementation of ECR: There have been over 61,000 shipments of 600 series items since October 2013. The 600 series exports are valued at...more

10/17/2014 - Export Controls Exports Trade Policy U.S. Commerce Department

ECR Episode IX: The Export Control Reform Turns One – What are Your Plans for the Big Celebration?

The Year Mark - Apparently, it is now fashionable among my peers to host elaborate parties in honor of the first birthdays of their children. I have attended a number of these fêtes, and been impressed to just what...more

10/14/2014 - BIS EAR Export Controls ITAR

Shelter from the Coming Storm: Anti-Corruption Compliance in European Public Procurement

A red sky at morning is the traditional harbinger of ill weather. From our vantage point in Brussels, we’ve scanned the horizon for signs of the future of anti-bribery enforcement activity in Europe. We’ve identified four...more

7/17/2014 - Anti-Corruption Enforcement EU European Commission Transparency

BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more

6/16/2014 - Anti-Money Laundering Bank Secrecy Act Banks BNP Paribas Chief Compliance Officers Enforcement Enforcement Actions Foreign Banks Sanctions

ECR Episode IX – Serving up the Third Round: The Next Wave of Export Control Reform Takes Effect on July 1, 2014

In the country pubs of Ireland, it has long been the practice of the barkeep to “stand the third round” for good customers, meaning to offer the third drink for free. The practice makes sense both as customer appreciation...more

6/13/2014 - Export Controls Exports Imports ITAR Trade Policy US Munitions List

ECR Series Episode VII: Livin’ in a Materials World – Changes to USML Category XIII

If you manufacture or export Auxiliary Military Equipment controlled under Category XIII of the U.S. Munitions List, you may rightly consider the category number unlucky. The current scope of Category XIII controls is broad...more

11/18/2013 - Export Controls Exports ITAR US Munitions List

Export Control Reform Series Episode II: The First Change – Reevaluating your ITAR Aircraft Parts

In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical...more

8/7/2013 - Aircraft Compliance Export Controls Exports ITAR US Munitions List

What Export Control Reform Means for You: Let Us Cl-EAR Up Changes to the ITAR – Episode I: The Basics – Five Points to Remember...

The first major wave of the much-discussed U.S. Export Control Reform measures will break on October 15, 2013 as the first round of rule changes take effect. While many in the affected industries expect that the October...more

7/12/2013 - Export Administration Regulations Export Controls Exports ITAR

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