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Today the U.S. Department of Commerce lifted its denial order on Chinese telecommunications firm ZTE Corp., allowing THE U.S. and other companies to resume most business with ZTE. The Commerce Department imposed the denial order in April after ZTE made false statements to the Commerce Department in connection with an earlier settlement agreement regarding violations of the U.S. embargoes on Iran and North Korea.  The denial order broadly barred U.S. companies from selling goods, software,…
Yesterday the Office of Foreign Assets Control (OFAC) formally rescinded General License H, requiring foreign subsidiaries of U.S. companies to wind down remaining business related to Iran by 11:59 pm EST on November 4, 2018.  After that date, foreign subsidiaries of U.S. companies and other owned or controlled entities will generally be prohibited from conducting any business related to Iran, including wind down activity.  This action was required following the President’s announcement on May…
On June 4, 2018, Russian President Vladimir Putin signed into law new counter-sanctions in response to U.S. sanctions imposed against Russia on April 6, 2018.  Under the new law, Putin may, among other things, sever ties with unfriendly countries and ban trade of goods with those countries.  The final version of the law stopped short of imposing criminal liability for compliance with U.S. and other foreign sanctions against Russian parties.  Companies are advised to consult…
Yesterday, the President issued a new Executive Order (E.O.) prohibiting certain financial transactions involving the Venezuelan government, including Petroleos de Venezuela, S.A. (PdVSA), the state-owned oil company.  Under the new rules, persons subject to U.S. jurisdiction are prohibited from engaging in transactions related to: (i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable; (ii) any debt owed to the Government of Venezuela that is pledged as collateral after the…
Today, the EC announced that it is moving forward with a package of measures to blunt the impact of renewed U.S. sanctions on Iran following the U.S. exit from the Joint Comprehensive Plan of Action (JCPOA).  Included in those measures is the planned activation of the EU blocking statute, which would bar EU companies from complying with the extraterritorial effects of U.S. sanctions requirements on Iran.  The statute is also intended to…