Beth Peters

Firm/Organization: Hogan Lovells

Blogs: Focus on Regulation, Global Media and Communications Watch

Latest Articles

OFAC Issues Press Release for a Finding of Violation Against State Street Bank and Trust Co. Where No Penalty was Assessed

By Andrea Fraser-Reid, Ajay Kuntamukkala & Beth Peters on June 5, 2019

OFAC has announced a Finding of Violation –and not a penalty–against State Street Bank and Trust Co. (SSBT) for processing 45 pension payments totaling under $12,000 on behalf of a pension plan participant who was a US citizen with a US bank account but was living in Iran.…

Focus on Regulation

Travel Ban Update: Appeals Court Upholds Temporary Halt on Enforcement

By Beth Peters, Sean Carlesimo & Nicholas Sparks on February 10, 2017

On February 9, 2017, the U.S. Court of Appeals for the Ninth Circuit issued an order denying the Federal Government’s emergency motion for a stay of the district court order temporarily pausing enforcement of the travel restrictions imposed by Executive Order 13769, “Protecting the Nation from Foreign Terrorist Entry into the United States.” As we reported in our January 30 and February 6 alerts, this Executive Order (1) blocks the entry to the U.S. of…

Focus on Regulation

Commerce Department Relaxes Restrictions on Certain Defense-Related and Other Exports to India; Tightens Hong Kong Documentation Requirements

By Beth Peters, Ajay Kuntamukkala, Stephen Propst, Anthony Capobianco, Brian Curran, Aleksandar Dukic & Adam Berry on January 24, 2017

On January 19, 2017, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) issued several amendments to the Export Administration Regulations (“EAR”) to implement the India-U.S. Joint Statement of June 7, 2016, recognizing the U.S. and India as Major Defense Partners, and making certain technical changes regarding Hong Kong’s Import and Export (Strategic Commodities) Regulations. The net result is a relaxation of licensing policy for certain national security and regional stability controlled items, including…

Focus on Regulation

Energy Department Revises its Part 810 Guidance on Nuclear Export Controls

By Amy Roma, Daniel Stenger, Ajay Kuntamukkala, Mary Anne Sullivan, Beth Peters, Anne Fisher & Sachin Desai on June 24, 2016

The Department of Energy (DOE) recently published its revised Part 810 Guidance on compliance with the amended Part 810 Regulations on nuclear export controls (10 C.F.R. Part 810). The 2015 amendments to the Part 810 Regulations represented the first comprehensive updating of DOE nuclear export control policy since 1986. Our previous review of the amended regulations can be found here. The revised Part 810 Guidance is useful to those interested in providing nuclear technology…

Focus on Regulation

FinCEN Designates North Korea as a Jurisdiction of Primary Money Laundering Concern, Triggering Additional Due Diligence Requirements for Financial Institutions

By Aleksandar Dukic & Beth Peters on June 16, 2016

Pursuant to the North Korea Sanctions and Policy Enhancement Act of 2016’s requirement that the Secretary of the Treasury determine whether North Korea is a jurisdiction of primary money laundering concern, on May 27, 2016, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) found that the Democratic People’s Republic of Korea (“DPRK” or “North Korea”) is a jurisdiction of primary money laundering concern under Section 311 of the USA PATRIOT Act. This designation is due…

Focus on Regulation

BIS and DDTC Amend Regulations Fire Control, Laser, Imaging, and Guidance and Control Equipment

By Ajay Kuntamukkala, Stephen Propst, Anthony Capobianco, Brian Curran, Aleksandar Dukic & Beth Peters on February 19, 2016

The Commerce Department’s Bureau of Industry and Security (“BIS”) and the State Department’s Directorate of Defense Trade Controls (“DDTC”) published proposed rules in the Federal Register today (BIS rules here; DDTC rules here) amending the Export Administration Regulations (“EAR”) and Category XII of the International Traffic in Arms Regulations (“ITAR”) as part of the President’s Export Control Reform (“ECR”) initiative. Specifically, a number of items in ITAR Category XII (Fire Control, Laser, Imaging,…

Focus on Regulation

BIS Lifts Licensing Requirements for Crude Oil Exports

By Ajay Kuntamukkala, Mary Anne Sullivan, C. Kyle Simpson, Stephen Propst, Anthony Capobianco, Brian Curran, Aleksandar Dukic & Beth Peters on December 28, 2015

The Bureau of Industry and Security (BIS) announced that crude petroleum is now classified as EAR99 and may be exported from the United States without an export license. This news follows the passage of the 2016 Consolidated Appropriations Act (H.R.2029) on December 18th, which ended the export ban on crude oil. For the text of the BIS announcement, please see below: “Effective immediately, pursuant to section 101 of Division O of the Consolidated Appropriations Act,…

Focus on Regulation

Sanctions Developments – Burundi and Liberia

By Patrick Ayad, Anthony Capobianco, Lourdes Catrain, Alexei Dudko, Aleksandar Dukic, Ajay Kuntamukkala, Robert Kyle, Louise Lamb, Beth Peters, Stephen Propst, T. Weymouth, Brian Curran, Catherine Robert, Falk Schoening, Jeanne Archibald, H.P. Goldfield & Jamie Rogers on November 30, 2015

On 23 November 2015, President Obama issued an executive order imposing targeted sanctions against certain persons or entities contributing to the insecurity and violence in Burundi. Read More: Sanctions Developments – Burundi and Liberia…

Global Media and Communications Watch

U.S. Government Steps Up Cybersecurity Efforts With New Rules for Export Controls, Economic Sanctions

By H. Deen Kaplan, Beth Peters, Stephen Propst, Anthony Capobianco, Ajay Kuntamukkala, Tom McGovern, Brian Curran, Michael Scheimer & Stephenie Gosnell Handler on July 6, 2015

With cybersecurity dominating the headlines, the U.S. government has taken several recent steps to target the national security threat posed by cybercriminals and hackers with new regulations aimed at curbing malicious actors online. With a series of proposed rules and an Executive Order, the U.S. government has begun a concerted effort (i) to rein in malicious cyber actors using export controls and sanctions regulations; and (ii) to better align U.S. export control regulations with the…

Focus on Regulation

U.S. Government Steps Up Cybersecurity Efforts With New Rules for Export Controls, Economic Sanctions

By Anthony Capobianco, H. Deen Kaplan, Ajay Kuntamukkala, Tom McGovern, Beth Peters, Stephen Propst, Brian Curran, Michael Scheimer & Stephenie Gosnell Handler on June 30, 2015

With cybersecurity dominating the headlines, the U.S. government has taken several recent steps to target the national security threat posed by cybercriminals and hackers with new regulations aimed at curbing malicious actors online. Read More: U.S. Government Steps Up Cybersecurity Efforts With New Rules for Export Controls, Economic Sanctions…

Beth Peters

OFAC Issues Press Release for a Finding of Violation Against State Street Bank and Trust Co. Where No Penalty was Assessed

Travel Ban Update: Appeals Court Upholds Temporary Halt on Enforcement

Commerce Department Relaxes Restrictions on Certain Defense-Related and Other Exports to India; Tightens Hong Kong Documentation Requirements

Energy Department Revises its Part 810 Guidance on Nuclear Export Controls

FinCEN Designates North Korea as a Jurisdiction of Primary Money Laundering Concern, Triggering Additional Due Diligence Requirements for Financial Institutions

BIS and DDTC Amend Regulations Fire Control, Laser, Imaging, and Guidance and Control Equipment

BIS Lifts Licensing Requirements for Crude Oil Exports

Sanctions Developments – Burundi and Liberia

U.S. Government Steps Up Cybersecurity Efforts With New Rules for Export Controls, Economic Sanctions

U.S. Government Steps Up Cybersecurity Efforts With New Rules for Export Controls, Economic Sanctions

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