Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel...more
6/21/2024
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Software ,
Technology Sector
On May 10, 2024, The Office of Foreign Assets Control (OFAC) has released a new proposed rule which would make significant changes to OFAC’s standard reporting, record-keeping, and license applications under U.S. sanction...more
On December 22, 2023, President Biden signed a new Executive Order (E.O. 14114) containing the latest round of sanctions against the Russian Federation. Shortly thereafter, Treasury Secretary Janet Yellen stated that the...more
In response to Russia’s ongoing aggression in Ukraine, both the United States and the European Union have imposed additional sanctions and further restricted exports to Russia and Iran. These new controls span many...more
2/28/2023
/ Economic Sanctions ,
Entity List ,
EU ,
Export Controls ,
Exports ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List ,
Trade Restrictions ,
UK ,
Ukraine
In response to Russia’s illegal declaration of annexations of Ukrainian territory, the United States and the European Union have imposed additional sanctions on Russia. U.S. Response On October 4, 2022, the U.S. government...more
On June 10, 2021, China enacted the Anti-Foreign Sanctions Law (“AFSL”), aimed at punishing countries that impose anti-China sanctions and the companies that comply with those sanctions. The law is effective immediately, and...more
We’ll give him this: President Trump has an ambitious trade agenda. This fire has many irons in it, and some of them are getting hot. Here at the Global Trade Law Blog, we’ve been following trade law for approximately 250...more
6/29/2018
/ Canada ,
CFIUS ,
China ,
Exports ,
FIRRMA ,
Foreign Direct Investment ,
Intellectual Property Protection ,
Investors ,
Iran Sanctions ,
Mexico ,
NAFTA ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Tariffs ,
Trump Administration
1. All sanctions on Iran that were in place before January 2016 will be re-imposed no later than November, 4 2018.
2. Secondary sanctions that penalize non-U.S. persons doing business with Iran will be reinstated.
3....more
5/14/2018
/ Economic Sanctions ,
Exports ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Foreign Relations ,
General Licenses ,
Goods or Services ,
Imports ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Trump Administration
What does decertification mean?
For the time being, decertification is a solely U.S. issue. Under the Iran nuclear agreement (known as the Joint Comprehensive Plan of Action, or JCPOA), Iran agreed to limits on its nuclear...more
10/13/2017
/ Automotive Industry ,
Banking Sector ,
Energy Sector ,
Financial Transactions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Shipping ,
Sovereign Debt
On July 17, 2017, the U.S. State Department certified that Iran continues to meet the conditions of the Iran nuclear agreement known as the Joint Comprehensive Plan of Action, or JCPOA. As a result, for the next 90 days, the...more
In our last post, we made a few cocky predictions about the new Trump Administration’s Cuba policy. We correctly asserted that the President would try to chart a narrow course between the Scylla of conservative Cuban-American...more
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
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
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
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 ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
UN Security Council ,
Vessels ,
WMD
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
Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the...more
One aspect of the dramatic shift in U.S. policy toward Cuba that has not been widely reported is a relaxation of the old rule prohibiting imports of most Cuban goods and services. Under the new rules, if your Cuban supplier...more
On January 15, 2015, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December...more
1/23/2015
/ Amended Legislation ,
Banking Sector ,
Barack Obama ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Embargo ,
Executive Orders ,
Export Controls ,
Exports ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Telecommunications ,
Travel Permits ,
U.S. Commerce Department ,
U.S. Treasury
New regulations on Cuba enter into force today, only 29 days after President Obama promised them. The liberalized provisions focus on support for private sector actors in Cuba. As we described here, the President announced on...more
Today, the Department of Treasury’s Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations to implement changes in U.S. policy toward Cuba announced by President Obama on December 17, 2014....more
OFAC Expands the 50 Percent Rule -
Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more
Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the...more
As the new year brings in a new term for the Obama Administration, the pace of Iran sanctions shows no sign of slowing. As we reported in October and November, Washington’s commitment to denying Iran the ability to advance...more
2/15/2013
/ Coal ,
FFI ,
IFCPA ,
Iran Sanctions ,
Metals ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Reinsurance ,
SDN List ,
Shipbuilding ,
Shipping ,
Software ,
Underwriting