Sentinel: Global News of Relevance To Entities & Individuals Engaging In Export, Customs & Trade - Summer 2010, Vol. VII, No. 3



- A Summer of Sanctions: World Leaders Respond to Iranian Obstinacy - Page 2

- New Department of Justice Guidance Seeks to Bolster Confidence in the Use of Independent Monitors — Page 6

- Round 2: Encryption Controls Streamlining — Page 6

- The British Are Coming! The British Are Coming! – Preparing for the Launch of the Bribery Act of 2010 — Page 7

- Government Procurement in China — Page 9

- Enforcement Highlights — Page 11

Excerpt from "A Summer Of Sanctions: World Leaders Respond To Iranian Obstinacy"

The global unease surrounding Iran’s development of nuclear capabilities has reached the tipping point. Tehran continues to assert that its nuclear development is intended purely for medical and energy-related purposes, while simultaneously expelling International Atomic Energy Agency inspectors from the country. The apparent subterfuge surrounding Iran’s nuclear intentions has forced global leaders into action. In recent months, the United Nations, the United States, and the European Union have aligned to denounce Tehran’s continued nuclear development, moving beyond diplomatic efforts to the imposition of resolutions and sanctions directed at Iran.

The new UN Resolution is a call for countries to closely monitor and cease specific interactions with Iran, but does not specifically address transactions that individuals and the business sector transact with Iran. However, both the U.S. and EU sanction regimes do specifically limit the permissible activity of the private business sector in relation to Iran. It remains unclear at this point what the practical impact upon the international business community will be, as many elements of both the U.S. and EU sanction regimes must be implemented by regulations that have yet to be released. Likewise, unless and until UN member nations enforce the UN security resolution, it remains unclear how the measure will impact Iran and those countries that choose to do business with Iran. Nevertheless, companies should plan now to ensure that their compliance programs are in line with the various sanction regimes....

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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