Implications of the Designation of Iran’s IRGC as a Foreign Terrorist Organization
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Coming Soon: New Export Controls on China?
Lost in the recent US-China trade headlines about tariffs, indictments, trade secrets theft, cyber espionage and other matters is a potentially important development lurking in last year’s US export controls statute. Essentially, Congress has directed the Executive Branch to review the current scope of US export controls on China and other countries subject to arms embargoes, and to implement changes to address any vulnerabilities. This review is supposed to be done and any regulatory changes implemented by…
Secretary Pompeo: More Russia Sanctions Are Coming … Sometime
On February 13, 2019, the State Department provided a summary of Secretary of State Mike Pompeo’s recent phone call with Russian Foreign Minister Sergey Lavrov, which stated that “Secretary Pompeo reiterated the US determination to hold Russia accountable for its use of a chemical weapon in Salisbury, UK through sanctions as required by the CBW Act.” The sanctions Secretary Pompeo referenced are the second round of sanctions slated to be imposed on Russia under the…
Foreign subsidiary trading with Iran? OFAC really means STRICT liability
On February 7, 2019, OFAC fined a Virginia-based company, Kollmorgen Corporation, for business that its recently-acquired Turkish subsidiary allegedly conducted in Iran after determining that Kollmorgen had undertaken “extensive preventative and remedial conduct” both before and after the acquisition in an effort to ensure the subsidiary complied with US sanctions. OFAC also found that Kollmorgen had “conduct[ed] an effective and extensive internal investigation and submit[ed] a comprehensive voluntary self-disclosure to OFAC.” Why, then, would OFAC…
New “Troika of Tyranny” Cuba Sanctions – More Bark Than Bite
US Sanctions Venezuelan Gold Sector
Today the President issued a new Executive Order targeting Venezuela, which is noteworthy in three respects:
1) It shows the US government wants to continue to increase the pressure on the Maduro regime through sanctions, but is continuing to act incrementally rather than imposing more sweeping restrictions that had been rumored in the past to be under consideration, such as broader oil sector sanctions.
2) It may have a significant impact on any companies dealing…
EU Promotes Export Controls and Sanctions Compliance Programs
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…
Trump Administration Sanctions Key Chinese Military Entity under Russia Authorities
Certain Iran Sanctions Reimposed after 90-Day “Wind-Down” Period Ends
President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions commitments under the JCPOA. Some of the re-imposed sanctions will be effective tomorrow, August 7; others will come back into…
ZTE Denial Order Lifted
The US Commerce Department’s Bureau of Industry and Security (BIS) terminated the ZTE Denial Order, effective today. As a result, ZTE is no longer subject to any specific US export control restrictions (except for ZTE Parsian, an Iranian affiliate that remains on the BIS Entity List). ZTE still faces a series of stringent requirements that will last 10 years, pursuant to its settlement with BIS, and any failure to comply could lead to a…