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Sri Lanka and Côte d’Ivoire Arms Embargoes Lifted – Possible Lifting of Côte d’Ivoire Sanctions?

By Peter Jeydel on May 10, 2016
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The State Department’s Directorate of Defense Trade Controls (DDTC) announced on May 4, 2016 that, effective immediately, it would start considering requests to conduct defense-related trade with Sri Lanka under the International Traffic in Arms Regulations (ITAR).  This reverses the previous US policy to deny ITAR license applications for Sri Lanka due to concerns about stability and human rights abuses during that country’s decades-long civil war.  The State Department had gained the authority to make this change after statutory restrictions on arms trade with Sri Lanka were not renewed in the applicable 2016 appropriations law.  The civil war largely ended in 2009, though elements of that persistent conflict continue to simmer.

The State Department announced the following day, on May 5, 2016, that it would implement the same policy of case-by-case review for ITAR license applications for Côte d’Ivoire (Ivory Coast), again reversing the previous policy of denial, which had been based on an arms embargo mandated by the United Nations Security Council (UNSC).  UNSC Resolution 2283 (April 28, 2016) had terminated the arms embargo based on improvements in the political and security situation in Côte d’Ivoire.

UNSC Resolution 2283 also terminated the Côte d’Ivoire travel and financial sanctions imposed by UNSC Resolution 1572 (November 15, 2004), which could provide an opening for the US Treasury Department’s Office of Foreign Assets Control (OFAC) to terminate some or all of the US sanctions on individuals in Côte d’Ivoire.  It remains to be seen what action OFAC will take, if any, in response to these UN developments.  OFAC currently maintains sanctions against six individuals in Côte d’Ivoire for contributing to violence and instability in that country, under Executive Order 13396 (February 7, 2006).  If OFAC did terminate its Côte d’Ivoire sanctions, that would be the second termination of a sanctions program in Africa in the past six months, after the Liberia program was terminated in November 2015.

Photo of Peter Jeydel Peter Jeydel

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC)…

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department. His practice spans all aspects of these regimes, including counseling, compliance, transactional advice, licensing and opinions, disclosures, and enforcement actions. He has also represented companies and individuals seeking de-listing from OFAC’s sanctions list. In addition, Pete has assisted clients in anti-corruption matters, including under the US Foreign Corrupt Practices Act (FCPA), and has experience handling reviews and investigations by the Committee on Foreign Investment in the United States (CFIUS).

Read Pete’s full bio.

Read more about Peter JeydelEmail
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  • Posted in:
    Government and Public Policy
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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