Anthony Rapa

Anthony Rapa

Anthony Rapa’s practice primarily involves international regulatory compliance, focusing on economic sanctions and export controls. His sanctions practice includes matters arising under US, EU, and UK economic sanctions regimes, including sanctions targeted at Russia and Iran. His export controls practice includes matters arising under the US International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), as well as similar EU and UK regulatory regimes.  Mr. Rapa has extensive experience with complex internal investigations, regulatory due diligence in support of international acquisitions and divestments, development of corporate compliance policies, submission of voluntary disclosures to enforcement authorities, providing compliance advice for complex cross-border transactions, and submission of license applications.

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Trump Administration Recertifies Iran’s Compliance with Nuclear Deal, Imposes Sanctions on IRGC-Linked Individuals and Entities

The Iran nuclear deal lives to see another day—but President Trump continues to express deep reservations regarding the agreement. Iran Nuclear Deal Certification On Monday, the Trump Administration reportedly certified Iran’s compliance with its nuclear-related obligations under the Joint Comprehensive Plan of Action (JCPOA) agreement, as required under the Iran Nuclear Agreement Review Act (INARA). … Continue Reading

BIS Amends EAR Based on Missile Technology Control Regime Plenary Agreements

On July 7, 2017, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) published a final rule amending the Export Administration Regulations (“EAR”) based on the 2016 Missile Technology Control Regime (“MTCR”) plenary agreements. The MTCR is a multilateral export control regime designed to control the export of certain goods and technology that … Continue Reading

Cuba Policy Changes Will Complicate New Business But Grandfather Existing Deals

In a much-anticipated speech on Cuba policy today, President Trump announced that, “effective immediately, I am canceling the last administration’s completely one-sided deal with Cuba.” That pronouncement notwithstanding, it appears that the Trump Administration’s new policy on Cuba (as set out in a Presidential Memorandum) will leave intact most of the changes made by the … Continue Reading

OFAC Extends Belarus Sanctions Relief

On April 28, 2017, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued a general license extending sanctions relief, which authorizes U.S. persons to engage in certain transactions with nine Belarus-based entities that have been designated as Specially Designated Nationals (“SDNs”), as well as other entities in which the nine entities have … Continue Reading

Trump Administration Certifies Iran’s Compliance with Nuclear Deal, but Initiates Review of Sanctions Relief

Will the Trump Administration “waive” goodbye to sanctions relief under the Iran nuclear deal? Last night, Secretary of State Rex Tillerson certified to Congress that Iran is in compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, but signaled that the Trump Administration is reviewing whether continued sanctions relief under the … Continue Reading

What’s in a Photo? And Thoughts on the UK Sanctions Scene

A couple of recent news items throw into sharp relief what we long have noted here at the International Compliance Blog—that economic sanctions are a key tool of a country’s national security and foreign policy, and can serve as an instrument by which to influence a broad array of events. First, take a look at this photo: … Continue Reading

OFSI Issues Regulations Implementing Civil Penalties for Financial Sanctions Violations

Following up on our previous post, yesterday the UK Office of Financial Sanctions Implementation (OFSI) issued regulations formally implementing the civil penalties framework set out in the Policing and Crime Act 2017.  OFSI has issued a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance issued in December … Continue Reading

UK to Move Towards US-Style Sanctions Enforcement with Upcoming Penalty Regulations

The UK’s Office of Financial Sanctions Implementation will soon issue regulations that could significantly alter the British sanctions enforcement environment, and bring it closer in line with the US’s approach to such violations.  On the heels of the newly-enacted Policing and Crime Act 2017, the regulations will introduce civil penalties for the violation of financial … Continue Reading

New Iran Sanctions Bills Backed by Bipartisan Group of Key Legislators

On March 23, 2017, members of Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. While several Iran sanctions bills have been introduced since the start of the year, these newly introduced bills are particularly notable due to their bipartisan support from an influential group of legislators. The bills represent legislative compromises … Continue Reading

Potential Designation of the IRGC as a Foreign Terrorist Organization and What It Could Mean for the Iran Deal

The Trump Administration recently floated the idea of designating Iran’s Islamic Revolutionary Guard Corps (IRGC) and the Muslim Brotherhood as Foreign Terrorist Organizations (FTOs).  This post focuses on the potential designation of the IRGC as an FTO, while a future post will discuss the implications of designating the Muslim Brotherhood as an FTO. The IRGC … Continue Reading

Waive it Goodbye? How the Trump Administration Might Attack the Iran Nuclear Agreement

President Trump has made no effort to conceal his disdain for the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, which he frequently has described as a “disaster” ranking among the worst deals in U.S. history. However, heated rhetoric notwithstanding, he often spoke on the campaign trail of improving the deal, rather … Continue Reading

Roundup of Recent AML/Sanctions Enforcement Actions

Capping off a year of robust sanctions enforcement, two recent enforcement actions highlight the risks of doing business with sanctioned countries, in particular Iran.  In December 2016, federal and New York state regulators initiated enforcement actions related to alleged sanctions violations involving Iran.  In the first enforcement action, Italy’s largest retail bank, Intesa Sanpaolo SpA … Continue Reading

BIS Eases Burma-Related Export Restrictions

On December 23, 2016, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) issued a final rule amending the Export Administration Regulations (15 C.F.R. Parts 730-774) to ease export restrictions against Burma consistent with Executive Order 13742, issued in October 2016. That executive order, which we previously have summarized, terminated the national emergency … Continue Reading

The Government Contractor Supply Chain Toolkit 2.0

Notwithstanding the uncertainty associated with the upcoming change in Administration, we decided to push forward with issuing the second edition of Steptoe’s Government Contractor Supply Chain Toolkit. Version 2.0 of the Toolkit (available here) provides an update on various federal rules and developments imposing supply chain requirements on federal contractors and subcontractors. The updated Toolkit … Continue Reading

What to Expect for Economic Sanctions Under President Trump?

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he … Continue Reading

Non-Member States Align with EU on Russia Sanctions Extension

On October 24, the EU announced that Liechtenstein, Norway, Montenegro, Albania, and Ukraine would renew sanctions against Russia in alignment with current EU policy.  As we have previously discussed, the EU prolonged restrictive measures against Russia in September, after determining that the situation in Ukraine did not merit a change in sanctions policy.  The asset … Continue Reading

Extend It Again, Sam: OFAC Continues Limited Belarus Sanctions Relief

The Treasury Department has extended limited sanctions relief related to certain Belarusian entities through April 2017. On October 18, 2016, the Office of Foreign Assets Control (OFAC) issued a general license which continues the partial easing of restrictive measures originally adopted in October 2015.  The relief, which was extended by six months, covers certain transactions … Continue Reading

BIS Adds Russian Companies to Entity List

Tomorrow, September 7, the U.S. Department of Commerce, Bureau of Industry and Security (BIS) will issue a final rule adding 81 entities to the BIS Entity List (15 C.F.R. Part 744, Supplement No. 4) under the Export Administration Regulations (EAR).  BIS is designating the companies, which are based in Russia, the Crimea region of Ukraine, India, … Continue Reading

New Russia Sanctions Designations

Yesterday, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) designated several new Russian and Ukrainian Specially Designated Nationals (SDNs) and Sectoral Sanctions Identification (SSI) List entities under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589).  The designations are explained in a press release and set out in detail in a web notice.  The … Continue Reading

UK Government Proposes Increased Penalties for Sanctions Violations

On February 10, 2016, a draft of the Policing and Crime Bill 2015-16 (“the Bill”) was introduced to the UK House of Commons and given its First Reading.  The Bill is a lengthy document covering a wide variety of issues, including financial sanctions, which are contained within Part 8. Alongside the Bill, the UK government … Continue Reading

OFAC Penalizes Barclays for Zimbabwe Sanctions Violations

On February 8, 2016, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $2,485,890 settlement with Barclays Bank Plc (“Barclays”).  According to the settlement announcement, Barclays processed 159 U.S.-dollar (“USD”)-denominated transactions on behalf of Barclays Bank of Zimbabwe Limited (“Barclays Zimbabwe”) between July 2008 and September 2013.  OFAC stated that … Continue Reading

Sanctions Partially Removed on Russian Entity to Allow Maintenance Subcontracts for Mi-17 Helicopters used in USG Programs

On September 2, 2015, the US Government announced the imposition of measures including the following against Rosoboronexport (ROE) (Russia) and any successor, sub-unit, or subsidiary thereof: “No department or agency of the United States Government may procure or enter into any contract for the procurement of any goods, technology, or services from [Rosoboronexport (ROE) (Russia) … Continue Reading