Insights on Export Controls & Economic Sanctions

Today the Department of the Treasury’s Office of Foreign Asset Controls issued a general license that effectively removes US sanctions against Sudan (North) effective January 17, 2017. 

On October 14, 2016, the Office of Antiboycott Compliance joined the 21st century and issued a Final Rule that permits electronic submission as an additional method to report requests.

Although the United States has had effective economic sanctions on North Korea for many years, the temporary softening of US sanctions in 2000 has given way to ever-increasing sanctions since 2008.

On April 15, the World Bank released updated public disclosures of its suspension and debarment practices against companies that violate its compliance directives.

Today, February 16, 2016, the US Department of Transportation and Cuban government officials signed a December 2015 agreement to restore commercial air travel. There have been no scheduled flights between the US and Cuba for over 50 years.

On January 16, 2016, the US Department of State and US Department of Treasury’s Office of Foreign Assets Control (OFAC) took two actions that impact the auto industry.

On January 16, 2016, the US Department of State and the US Department of Treasury’s Office of Foreign Assets Control (OFAC) announced the lifting of certain US sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (JCPOA).

Saturday marked “Implementation Day” when the International Atomic Energy Agency (IAEA) verified that Iran has fulfilled its nuclear-related obligations under the JCPOA. Implementation Day also means the first of the domino impact to US sanctions.

Sunday, October 18, 2015 marked the official “Adoption Day” of the July 14, 2015 Joint Comprehensive Plan of Action (JCPOA).

The Commerce Department’s Bureau of Industry & Security and the Treasury Department’s Office of Foreign Assets Control released amendments to the Export Administration Regulations and the Cuban Assets Control Regulations to further implement President Obama’s new Cuba policy to ease sanctions.

Earlier today, the United States, China, France, Russia, UK, and Germany (the “P5+1” nations) reached a historic final agreement with Iran to limit its nuclear program in exchange for sanction relief: the Joint Comprehensive Plan of Action Agreement (JCPOA).

On May 5, 2015, the Bureau of Industry and Security and the Directorate of Defense Trade Controls issued proposed rules concerning the transfer of certain items from US Munitions List Category XII to the Commerce Control List as part of the President’s Export Control Reform Initiative.

Iran and the United States, along with Russia, China, France, the UK, and Germany announced that they have reached an agreement on the key parameters for a Joint Comprehensive Plan of Action regarding the Iran nuclear program in exchange for the termination of certain sanctions.

Based on recent votes in Congress, the possibility of a partial shutdown of Department of Homeland Security (DHS) activities for at least a brief period of time is looming larger. On February 27, 2015, Congress extended DHS funding for one week.

The long-awaited final Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS) provisions modifying the Human Trafficking regulations were published on January 29, 2015.

In 2014, the Departments of State and Commerce implemented final rules that overhauled 11 United States Munitions List (USML) Categories. These changes have affected a wide range of industries.

The Treasury Department’s Office of Foreign Assets Control and the Commerce Department’s Bureau of Industry and Security released their much-anticipated regulations governing trade with Cuba, and they were published in the Federal Register and became effective on January 16, 2015.

Canada’s Department of Foreign Affairs, Trade, and Development announced an enhanced Corporate Social Responsibility Strategy when it released a report entitled “Doing Business the Canadian Way: A Strategy to Advance Corporate Social Responsibility in Canada’s Extractive Sector Abroad.”

The United States and the European Union imposed additional sanctions on Russia and Crimea.

In a live press conference yesterday, President Barack Obama announced the beginning to a thaw in more than 50 years of chilly relations with Cuba.

On November 7, 2014, the Department of Commerce’s Bureau of Industry and Security (BIS) amended its Export Administration Regulations (EAR) to impose license requirements on the export, re-export, or transfer (in-country) of certain items to or within Venezuela when intended for a “military end use”

Import managers and compliance personnel can now be held personally liable in circumstances other than fraud for imports that violate US custom laws.

Investment Services Targeted, Sectoral Sanctions Move Debt Sanctions from 90 to 30 days, Certain Oil Exploration/Production Exports and Services Prohibited