Archives: Economic Sanctions

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Trump Administration Uses New Approach in Syria Sanctions Action

On April 24, 2017, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 271 employees of Syria’s Scientific Studies and Research Center (“SSRC”) pursuant to Executive Order 13582 (targeting the Syrian government and its supporters).  The designations are part of the Trump Administration’s response to the April 4, 2017 chemical weapons … 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a press release, regulations regarding civil penalties, responses received to OFSI’s request for consultation regarding draft guidance issued in December … Continue Reading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

ZTE Settlement Marked by Record Penalty and Lessons Learned

China’s Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Limited, and their subsidiaries and affiliates, (collectively, ZTE), reached a historic combined $1.19 billion settlement with the US government on March 7, 2017.  This settlement resolves export controls and sanctions violations associated with shipments of US-origin equipment to Iran and North Korea.  ZTE pled guilty to … 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

ZTE Enters Multi-Agency Settlement to Resolve Sanctions and Export Controls Allegations

On March 8, 2016, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) added major Chinese telecommunications company Zhongxing Telecommunications Equipment (“ZTE”) and three ZTE affiliates to the BIS Entity List, alleging that the ZTE entities developed a scheme to re-export controlled items to Iran in violation of US export controls and sanctions … 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

New US Sanctions on Iran: More of the Same, but Tensions Are Rising

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated 25 additional individuals and entities on its list of Specially Designated Nationals and Blocked Persons (SDNs) on February 3, 2017.  Alone the new designations do not constitute a departure from past policy or practice, but they could indicate the possibility of such … 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

US Lifts Nearly All Economic and Financial Sanctions on Sudan

The US Treasury Department’s Office of Foreign Assets Control (OFAC) published an amendment to the Sudanese Sanctions Regulations (SSR), 31 C.F.R. Part 538, on January 17, 2017.  The amendment authorizes all transactions that were previously prohibited under the SSR, including transactions involving the Government of Sudan.  OFAC’s SSR amendment comes as a broad general license … 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

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

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

DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program

Members of the Steptoe International Regulation and Compliance team, Tom Best, Jack Hayes, Andy Irwin, Ed Krauland, and Lucinda Low co-authored “DOJ Export Controls and Economic Sanctions Enforcement Guidance Likely to Impact Government Contractors, Parallels FCPA Pilot Program” for Thomson Reuters Briefing Papers (No. 16-12).  The paper discusses a memorandum by the US Department of … Continue Reading

Iran Sanctions Extension Act Becomes Law without President Obama’s Signature

On December 15, 2016, the White House Press Secretary released a statement that President Obama would allow the Iran Sanctions Extension Act (H.R. 6297) to become law, but that the President declined to sign it.  This bill extends the current Iran Sanctions Act (ISA) through December 31, 2026 and passed Congress with overwhelming support, passing the … 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

UK Government Seek Consultations on New Civil Penalties For Violations of Economic Sanctions

The UK’s HM Treasury is holding a consultation, which is open for comment through January 26, 2017, on the process for the imposition of civil penalties for breaching financial sanctions.  This is a major departure from the current law, which has not produced many enforcement actions, as it currently only allows for criminal enforcement of sanctions … 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
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