- A President Trump will have authority to reinstate sanctions lifted by the Iran Nuclear Deal as well as revoke certain authorizations provided for business with Iran.
- Several economic and geopolitical factors may...more
12/8/2016
/ Business Opportunities ,
Corporate Counsel ,
Executive Orders ,
Global Market ,
International Relations ,
International Treaties ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Weapons ,
Office of Foreign Assets Control (OFAC) ,
Presidential Elections ,
SDN List ,
Trump Administration
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 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
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
- 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
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 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) ,
Federal Trade Commission (FTC) ,
International Data Transfers ,
Ombudsman ,
Personal Data ,
Schrems I & Schrems II ,
Surveillance ,
U.S. Commerce Department ,
US-EU Safe Harbor Framework
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
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
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 ,
National Security Agency (NSA) ,
Nuclear Power ,
Obama Administration ,
Sanctions ,
Search Engines ,
Source Code ,
Visas
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
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 ,
Department of Justice (DOJ) ,
Government Investigations ,
Plea Agreements ,
Serious Fraud Office (SFO) ,
Suspensions & Debarments ,
UK ,
UK Bribery Act
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
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
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
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
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
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
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
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
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
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
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
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