Peter Jeydel

Peter Jeydel

Peter Jeydel‘s practice focuses on US export controls and economic sanctions, including the Commerce Department’s Export Administration Regulations (EAR), the State Department’s International Traffic in Arms Regulations (ITAR), and sanctions regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC) and the State Department.  His practice spans all aspects of these regimes, including counseling, compliance, transactional advice, licensing and opinions, disclosures, and enforcement actions.  He has also represented companies and individuals seeking de-listing from OFAC’s sanctions list.  In addition, Mr. Jeydel has assisted clients in anti-corruption matters, including under the US Foreign Corrupt Practices Act (FCPA), and has experience handling reviews and investigations by the Committee on Foreign Investment in the United States (CFIUS).

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OFAC Penalizes AIG’s Voluntary Disclosure of Overly “Narrow” Exclusion Clauses and Single Shipment Policies

On June 26, 2017, American International Group, Inc. (AIG) agreed to a $148,698 civil settlement with OFAC based on a voluntary disclosure of 555 apparent violations of OFAC’s Iran, Sudan, Cuba and Weapons of Mass Destruction Proliferators economic sanctions programs.  AIG processed approximately $396,530 in premiums and paid claims on policies covering maritime shipments of … Continue Reading

Back to the Future on “Extraterritorial” Sanctions on Russian Pipelines?

Earlier this month, after the Senate overwhelmingly passed a bill that would authorize (and in some cases mandate) sanctions on foreign energy firms that participated in certain Russian energy projects, the Governments of Germany and Austria issued a joint statement that they “cannot accept a threat of extraterritorial sanctions, illegal under international laws, against European … Continue Reading

What Can We Say About The Trump Administration’s First Russia Sanctions?

The Treasury Department’s Office of Foreign Assets Control (OFAC) today designated 38 individuals and entities in order to “reinforce[] existing sanctions on Russia.”  This announcement came while President Trump was meeting the President of Ukraine in the White House.  These were the first new sanctions under the Trump Administration related to the conflict in Ukraine … 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

Senate Moving Forward with Strong Russia Sanctions Bill Targeting Energy and Financial Services

Last night, a key group of bipartisan senators reached agreement on, and introduced, a Russia sanctions amendment to a broader sanctions bill focused on Iran, which could be voted on as early as this week.  It is called the Countering Russian Influence in Europe and Eurasia Act of 2017 (CRIEEA).  The CRIEEA does not adopt … Continue Reading

OFAC Takes Sanctions Jurisdiction Into Uncharted Waters

On February 3, 2017, the US Treasury Department’s Office of Foreign Assets Control issued a finding of violation against Taiwan-based B Whale Corp. (BWC), a member of the Taiwan-based shipping company TMT Group. The finding of violation was issued for activity occurring entirely outside the United States, based on the jurisdictional finding that “BWC was … Continue Reading

Commerce Department Eases Certain Export Controls on India

Tomorrow, the Commerce Department’s Bureau of Industry and Security (BIS) will ease certain U.S. export controls on India, as part of the U.S. commitments under the India–U.S. Joint Statement of June 7, 2016, which recognized the United States and India as Major Defense Partners.  BIS is amending the Export Administration Regulations (EAR) to establish a … Continue Reading

Groundbreaking Russia Sanctions Bill Introduced in the Senate

A bipartisan group of US Senators introduced a bill on January 11, 2017 – the Countering Russian Hostilities Act of 2017 – that would impose unprecedented sanctions on Russia and persons and entities conducting certain types of business involving Russia.  This bill would codify into law most of the existing sanctions targeting Russia, making it … Continue Reading

New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement

Steptoe’s Meredith Rathbone and Peter Jeydel co-authored an article in Risk & Compliance, “New DOJ Guidance Could be a Game Changer for Export Controls and Sanctions Enforcement.”  The article was published in the January-March issue and centers on how the US Department of Justice’s guidance may cause difficulties and new risks for industries. For more … Continue Reading

New US Cyber Sanctions on Russia

Obama Expands Cyber Sanctions to Cover Election Hacking, Then Uses it to Sanction Russian Intelligence Agencies and Others On December 29, 2016, the President amended Executive Order 13964, which was originally issued in April 2015, to explicitly authorize sanctions on those found to be “tampering with, altering, or causing a misappropriation of information with the … Continue Reading

DDTC and BIS Publish Long-Awaited Final Rules for Category XII: Night Vision and Cameras

On October 12, 2016, the State Department’s Directorate of Defense Trade Controls (DDTC) and the Commerce Department’s Bureau of Industry and Security (BIS) published companion final rules to amend Category XII of the United States Munitions List (USML) and move some less sensitive items to the Commerce Control List (CCL).  The final rules will become … 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

OFAC Sets Out 180-Day Wind Down Period if Iran Sanctions “Snap Back”

On December 15, 2016, OFAC amended Frequently Asked Question (FAQ) No. M.5 to provide more clear guidance about how it would treat business activities in Iran by non-U.S., non-Iranian persons should those activities become prohibited or sanctionable as a result of a “snapback” into effect of economic sanctions provisions that are currently modified or suspended … Continue Reading

U.S. Maintains Arms Embargo on Myanmar Due to Religious Freedom, After Sanctions Lifted

On December 6, 2016, the State Department’s Office of International Religious Freedom published a notice in the Federal Register announcing that it would maintain the unilateral U.S. arms embargo on Myanmar (which the U.S. Government still calls “Burma”) pursuant to the International Religious Freedom Act of 1998 (Pub. L. 105–292), as amended.  Along with Myanmar, … Continue Reading

UN Tightens the Screws on North Korea with Additional Trade and Banking Sanctions

On November 30, 2016, UN Security Council Resolution (UNSCR) 2321 was adopted, pushing the limits on how far international economic sanctions can go in isolating the North Korean regime without entirely collapsing the country’s economy.  The resolution also lays out a handful of additional legal restrictions that will be pertinent for US and international stakeholders … Continue Reading

U.S. Removes Restrictions on Government-to-Government Assistance for Myanmar

As we discussed in a previous post, the United States terminated its economic sanctions program targeting Myanmar (which the U.S. Government still calls “Burma”) on October 7, 2016.  Building upon the normalization of relations that led to the lifting of sanctions, the U.S. Government has determined that the circumstances now allow for a resumption of … Continue Reading

Stephen Heifetz and Peter Jeydel on the Cuba Embargo in The Hill

Today, Steptoe’s Stephen Heifetz and Peter Jeydel were published in The Hill with an op-ed piece “Time to Finally End the Cuba Embargo.”  They argue that the President has the executive authority to lift most, if not all, of the embargo, in the wake of the 25th annual UN General Assembly vote condemning it.  For … Continue Reading

US Lifts All Economic and Financial Sanctions on Myanmar (Burma), But Risks Remain

Following up on our previous post, on October 7, 2016, President Obama issued an Executive Order (which we will refer to as the New EO), lifting all US economic and financial sanctions on Myanmar.  This order follows a September 14, 2016 announcement on which we previously advised.  The Department of the Treasury’s Office of Foreign … Continue Reading

Côte d’Ivoire Sanctions Program Terminated

Yesterday President Obama issued an Executive Order removing the U.S. sanctions program on Côte d’Ivoire.  As we stated in a previous post, this move has been anticipated since April, when the UN Security Council passed Resolution 2283 terminating the UN arms embargo and travel and financial sanctions on Côte d’Ivoire based on improvements in the political … Continue Reading

The Cost of Non-Compliance in the International Regulatory Space Has Just Gone Up

Today, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued a rule increasing penalties for violations of its economic sanctions regulations.  This type of penalty increase should now occur on an annual basis. The maximum statutory penalty for each violation under most of OFAC’s sanctions programs, other than Cuba and a few others, is … Continue Reading

Massachusetts Company Hit with ITAR Penalty for a Single Individual Deemed Export Violation; Settlement Highlights Importance of Timely Disclosure

In its second enforcement action this year, on June 20th, the State Department’s Directorate of Defense Trade Controls (DDTC) reached a $100,000 settlement with Massachusetts-based Microwave Engineering Corporation.  Despite the small penalty amount, this case is noteworthy in several respects. … Continue Reading

French Senate Overwhelmingly Votes to Roll Back Russia Sanctions

Yesterday, the French Senate voted 302-16 to “gradually and partially” lift sanctions on Russia, despite opposition from the Hollande government.  While this vote has no legal effect, it was a strong showing of political opposition in France to the continuing EU sanctions.  The US and EU have largely remained aligned on their policy that Russia … Continue Reading
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