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 Designates North Korea as a ‘State Sponsor of Terrorism,’ Makes Additional Sanctions Designations

On November 20, 2017, President Trump announced that North Korea would be designated a “state sponsor of terrorism.”  The only other countries with this designation are Syria, Iran, and Sudan.  The president also stated that the United States would announce the imposition of additional sanctions on Pyongyang.  The next day, the US Department of the … Continue Reading

Russian Sanctions Update: OFAC Amends Directive 4 and Updates FAQ Guidance

On October 31, 2017, the Office of Foreign Assets Control (OFAC) took a number of actions to implement the Countering Russian Influence in Europe and Eurasia Act (CRIEEA) (also known as the Countering America’s Adversaries Through Sanctions Act (CAATSA), a larger sanctions statute of which CRIEEA was a part).  As part of this, OFAC amended Directive … Continue Reading

President Trump Outlines New Strategic Approach Regarding Iran

In a speech today, President Trump announced the result of his Administration’s strategic review of foreign policy towards Iran, including the Joint Comprehensive Plan of Action (“JCPOA”) implemented by the Obama administration in January 2016.  As set out in a White House fact sheet, the Trump Administration will seek to expand the focus of U.S. … Continue Reading

Bank Warranties: The Other Sanctions Regulations

Imagine, for a moment, that your company has achieved a state of compliance nirvana. Through the diligent efforts of compliance personnel and counsel, the company has assessed its economic sanctions and export control risks, implemented policies and procedures to prevent unlawful activity, and provided compliance training to employees.  With those measures in place, the company … Continue Reading

EU Raises Specter of Blocking Regulation as Trump Administration Ponders JCPOA

In a panel hosted by the Atlantic Council last week, the EU Ambassador to the United States, David O’Sullivan, stated that the European Union could block U.S. sanctions on Iran if the United States pulls out of the Joint Comprehensive Plan of Action (“JCPOA”). The U.S. Congress built in a requirement under the Iran Nuclear Agreement Review … Continue Reading

Settlement Points to Potentially Expansive View of Importation of Iranian Services by OFAC

On August 10, 2017, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with IPSA International Services, Inc. (“IPSA”) to resolve apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”).   The apparent violations include importation of Iranian-origin services in violation of § 560.201 and engagement in transactions or dealings related … Continue Reading

WorldECR Publishes Article on EAR License Exceptions

Steptoe’s Ed Krauland and Anthony Rapa authored an article on Export Administration Regulations (EAR) license exceptions published in WorldECR’s July 2017 issue. The article discusses the pros and cons of license exceptions, which can offer exporters a host of cost, time, and efficiency benefits. They argue that, when mastered, these license exceptions can be a … Continue Reading

Supreme Court to Decide Whether Firms can be Sued in Human Rights Cases

The unsettled question of whether corporations may be held liable for international human rights abuses may finally, after a tortuous deviation, be addressed by the Supreme Court in the case of Jesner v. Arab Bank. The case, on appeal from the United States Court of Appeals for the Second Circuit in New York, contains allegations … Continue Reading

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
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