The Trade Practitioner

International Trade Current Events and Compliance Tools

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By: Squire Patton Boggs

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Bryan Schwartz
Daniel Waltz
Frank Samolis
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UPDATE:  BIS is extending the public comments deadline on emerging technology export controls from December 19 this year to January 10, 2019, per an unpublished Federal Register notice released on December 13. The proposed rule will officially appear in the Federal Register on December 14. Posted on November 26, 2018 On November 19, 2018, the US Department of Commerce’s (Commerce) Bureau of Industry Security (BIS) published in the Federal Register an advance notice of proposed rulemaking …
On October 15, 2018, the Council of the EU adopted new sanctions against people and entities involved in providing financial, technical or material support for or otherwise involved in any business transaction related to proliferation of chemical weapons. In particular, EU sanctions provide for the freezing of assets for sanctioned people/entities.…
In October 2018, the EU decided to amend its list of sanctioned entities and persons in the following countries: Burundi, Guinea and North Korea. Further, the European Commission added new persons to sanctions directed against the ISIL (Da’esh) and Al-Qaida organizations, and removed restrictions imposed on one Iraqi entity. The up-to-date consolidated list of all entities and people subject to EU sanctions can be found on the website of the European Commission.…
On October 24, 2018, Office of Foreign Assets Control (OFAC) announced that, together with the Department of State, it is extending the Belarus General License 2F’s expiration date. The general license authorizes transactions with certain entities in Belarus pursuant to Executive Order 13405. However, the general license does not authorize the release of blocked property. The expiration date for the general license is October 25, 2019.…
The US Department of Commerce, Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to reflect the 2017 changes to the dual-use controls adopted during the 2017 Wassenaar Arrangement Plenary Meetings. As set forth in the October 24, 2018 announcement in the Federal Register, the amendments revise 50 Export Control Classification Numbers (ECCNs) throughout the Commerce Control List (CCL), remove two ECCNs from Category 6 of the CCL, correct ECCN 3A991, and change ECCN 2B206 to maintain Nuclear…
On October 12 and October 19, 2018, Office of Foreign Assets Control (OFAC) extended the expiration date of certain Ukraine-related General Licenses. Specifically, OFAC issued General License 13E and 13F, Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, which extend the deadline for certain transactions with GAZ Group and with  RUSAL PLC until December 12, 2018. In addition, OFAC issued General License 14B, Authorizing Certain Activities Necessary to Maintenance or Wind Down…
On October 16, 2018, OFAC announced sanctions “against a vast network of businesses providing financial support to the Basij Resistance Force (Basij), a parliamentary force subordinate to Iran’s Revolutionary Guard Corps (IRGC).” According to OFAC, the Basij militia recruits, trains and deploys child soldiers to fight in IRGC conflicts across the region. Bonyad Taavon Basij, an Iran-based network, is comprised of at least 20 corporations and financial institutions (list of Iran-related designations).…
On October 5, 2018, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) announced an agreement with JPMorgan Chase Bank, N.A. (JPMC) to settle potential civil liability arising from 87 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. According to OFAC, “the transactions were net settlement payments, of which a very small portion appears to have been attributable to interests of airlines that were at…