Keith Huffman

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Keith Huffman partners with companies from across the globe to help ensure their compliance with export controls, economic sanctions, anti-boycott regulations and anti-corruption laws. Keith has extensive experience helping clients comply with the US Commerce Department’s Export Administration Regulations (EAR), the US State Department’s International Traffic in Arms Regulations (ITAR) and economic sanctions regulations administered by the US Treasury Department’s Office of Foreign Assets Control (OFAC). He also assists clients in anti-corruption matters by designing tailored compliance programs, assisting with regulatory due diligence in support of international acquisitions and conducting internal investigations. One of Keith’s jobs before joining Steptoe was working in the US Senate focusing on trade, defense and foreign policy issues.

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Latest Articles

On October 3, 2018, the International Court of Justice (“ICJ” or the “Court”), the principal judicial organ of the United Nations, issued an Order ruling partly in favor of Iran on Iran’s request for provisional measures against the US for its May 8, 2018 withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-imposition of sanctions on August 6, 2018. On July 16, 2018, Iran instituted proceedings against the US with regard to…
Effective yesterday, as part of the President’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the Office of Foreign Assets Control (OFAC) revoked several general authorizations that had been issued as part of the JCPOA, and amended the Iranian Transactions and Sanctions Regulations (ITSR) to implement “wind down” periods for persons who had previously relied on these authorizations.   In addition, OFAC updated its Frequently Asked Questions (FAQs) providing guidance on the JCPOA…
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 –…
In light of the recent protests in Iran, a UK press report has recently drawn attention to a motion – known as Early Day Motion 483 – filed in October by a Conservative Party MP to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organisation. The motion calls upon the UK Government to include the IRGC on the list of “proscribed organisations” and to impose “punitive measures” against its individuals.  Since its filing, the…
In a panel hosted by the Atlantic Council last week, the EU Ambassador to the United States, David O’Sullivan, stated that the European Union could block U.S. sanctions on Iran if the United States pulls out of the Joint Comprehensive Plan of Action (“JCPOA”). The U.S. Congress built in a requirement under the Iran Nuclear Agreement Review Act (INARA) that the President certify every 90 days that Iran is in compliance with its nuclear-related obligations under…