Guy Soussan

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Guy Soussan advises clients on various aspects of EU and French export control regulations, including controls and licensing regimes for both military and commercial products and technologies. His export practice covers compliance development and implementation, internal investigations, and enforcement matters, including voluntary disclosures. He also provides advice and assistance with EU economic sanctions targeting specific countries such as Iran, Libya, Syria, and most recently, Ukraine and Russia. His experience covers a wide range of industries, including manufacturing, energy, telecommunications, banking and insurance, petroleum and petro-chemicals, aerospace, and defense. He has conducted internal compliance audits, provided assistance on company compliance programs, and counseled clients on the application of the rules to specific transactions.

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Latest Articles

The European Commission (the Commission) recently issued draft guidelines on the core elements that European industry should take into account when implementing internal export controls and sanctions compliance programs.  The guidance – which is legally non-binding – will be finalized upon the results of a public consultation providing the opportunity for EU exporters to comment on its core elements.  Companies can participate by responding to a survey until November 15.  It is the intention of…
In response to President Trump’s Executive Order re-imposing certain Iran-related sanctions, summarized in our recent post, the EU has expanded the scope of the EU Blocking Statute to cover certain US Iran-focused sanctions.  On August 7, immediately following the US government’s re-imposition of certain Iran-related sanctions, the Commission Delegated Regulation (EU) 2018/1100 amending the annex to the EU Blocking Statute was published in the EU Official Journal and entered into force. In addition to…
On June 6, and in furtherance of its May 16 announcement, the European Commission adopted a delegated act to amend the annex to the EU Blocking Statute by adding within its scope US Iran-related secondary sanctions that have extra-territorial application.  The delegated act will enter into force once it is published in the EU Official Journal – probably well before the August 16 deadline set out for the re-imposition of the US secondary sanctions –…
On May 18, the Commission announced the launch of the formal process to activate the EU “blocking statute” (Council Regulation (EC) 2271/96) by updating the list of US sanctions on Iran falling within its scope. The Commission starts the formal process after receiving unanimous informal support from the leaders of the EU Member States to a package of measures that the Commission has proposed to protect the interests of EU companies investing in Iran and…
On January 12, President Trump announced that he was reissuing statutory waivers necessary to continue certain sanctions relief pursuant to the Joint Comprehensive Plan of Action (“JCPOA” or Iran nuclear deal), but stated that this was the last time he would reissue such waivers unless his concerns over the agreement were addressed.  On the same day, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC”) designated 14 individuals and entities for engaging in…
As tensions continue to escalate between the United States and North Korea, and President Donald Trump and Kim Jong-Un trade increasingly tense lobs, the United Nations, the EU, the United States, and other countries continue to impose further stringent sanctions against North Korea to a breaking point (for details on UN Security Council Resolution 2375 and the US’s new sanctions, see our previous advisory). In our most recent advisory, we provide an overview…
In light of the continuing deterioration of the democracy and human rights in Venezuela, the Foreign Affairs Council of Ministers agreed on November 13 to adopt a first set of sanctions measures against Venezuela. These measures are reflected in two EU legal instruments, Council Regulation (EU) 2017/2063 of 13 November 2017 concerning restrictive measures in view of the situation in Venezuela and Council Decision (CFSP) 2017/2074 of 13 November 2017 concerning restrictive measures in view of the
The European Commission issued on September 13th 2017 a Proposal for a Regulation establishing a framework on the screening of foreign direct investments (FDI) into the EU. The objective of this proposal is two-fold: pushing third countries to open their domestic markets to EU investments, and protecting EU assets against foreign takeovers detrimental to the essential interests of the EU or of its Member States.  The Commission proposes to achieve this by introducing information…
The Council of the European Union has decided to prolong by 6 months the application of EU restrictive measures targeting actions against Ukraine’s territorial integrity, sovereignty and independence. These sanctions consist of an asset freeze and a travel ban against 146 persons and 37 entities.  They have been extended until 15 March 2017. The measures had been introduced in March 2014 and were last extended in March 2016.The assessment of the situation did not justify…
The EU has extended, today, economic sanctions targeting specific sectors of the Russian economy to 31 January 2017.  The extension is set out in Council Decision (CFSP) 2016/1071. The sanctions concern the financial, energy and defence sectors, as well as dual-use goods, and have been extended because the Council has assessed that the Minsk agreements concerning military activity in the Donetsk and Luhansk regions of Ukraine have not been respected.…