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Today the U.S. Office of Foreign Assets Control (OFAC) amended the Iranian Transactions and Sanctions Regulations (ITSR, 31 C.F.R. Part 560) to fully re-impose U.S. sanctions on Iran following a wind down period that expired yesterday, November 4, 2018.  OFAC also issued new FAQs for foreign affiliates of U.S. companies and non-U.S. companies. Foreign affiliates of U.S. companies are now generally prohibited from engaging in transactions directly or indirectly involving Iran, Iranian companies or…
It has always been a possibility that the United Kingdom would crash out of the European Union on 30 March 2019 but “no deal” preparation is now highly recommended by both sides.  For organisations that export dual use items, the possibility of the UK becoming a “third country” vis-à-vis the EU without an exit agreement or transition period means an overnight need for export licenses where none are required today. Seasoned international businesses understand that…
Yesterday the U.S. government announced that it would implement new sanctions against Russia mandated under the Chemical and Biological Weapons Act of 1991 (the CBW Act) following the apparent deployment of a chemical weapon on British soil by Russia. The first round of sanctions, which are expected to come into force on or around August 22, will prohibit many exports and reexports of goods, software, or technology to Russia controlled for national security reasons under…
A set of changes to the U.S. dual use export control rules makes exporting sensitive goods, software, and technology to India less burdensome. Over the last several years, India has joined three of the four major multilateral export control regimes – the Missile Technology Control Regime (MTCR), the Wassenaar Arrangement, and the Australia Group.  In response to India’s ascension to these agreements, the United States has amended the Export Administration Regulations (EAR) to ease export…
Tomorrow the United States will re-impose a set of secondary sanctions on Iran as the newly amended EU blocking statute comes into force. Following the U.S. withdrawal from the multilateral Iran nuclear deal (the Joint Comprehensive Plan of Action or JCPOA), the United States is set to re-impose a raft of secondary sanctions targeting Iran.  The secondary sanctions are designed to penalize non-U.S. companies for conducting certain types of business involving Iran, even in cases…