Keith Huffman

Keith Huffman

Keith Huffman partners with companies from across the globe to help ensure their compliance with export controls, economic sanctions, anti-boycott regulations and anti-corruption laws. Keith has extensive experience helping clients comply with the US Commerce Department’s Export Administration Regulations (EAR), the US State Department’s International Traffic in Arms Regulations (ITAR) and economic sanctions regulations administered by the US Treasury Department’s Office of Foreign Assets Control (OFAC). He also assists clients in anti-corruption matters by designing tailored compliance programs, assisting with regulatory due diligence in support of international acquisitions and conducting internal investigations. One of Keith’s jobs before joining Steptoe was working in the US Senate focusing on trade, defense and foreign policy issues.

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US Withdraws from Treaty of Amity with Iran after International Court of Justice Imposes Limited Provisional Measures Against US Iran Sanctions

On October 3, 2018, the International Court of Justice (“ICJ” or the “Court”), the principal judicial organ of the United Nations, issued an Order ruling partly in favor of Iran on Iran’s request for provisional measures against the US for its May 8, 2018 withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-imposition … Continue Reading

OFAC Revokes General License H and Takes Other Steps to Continue to Implement the US Withdrawal from the JCPOA

Effective yesterday, as part of the President’s decision to withdraw from the Joint Comprehensive Plan of Action (JCPOA), the Office of Foreign Assets Control (OFAC) revoked several general authorizations that had been issued as part of the JCPOA, and amended the Iranian Transactions and Sanctions Regulations (ITSR) to implement “wind down” periods for persons who … Continue Reading

EU Extends the Scope of EU Blocking Statute to Protect Against Extra Territorial Application of US Re-Imposed Sanctions on Iran

On June 6, and in furtherance of its May 16 announcement, the European Commission adopted a delegated act to amend the annex to the EU Blocking Statute by adding within its scope US Iran-related secondary sanctions that have extra-territorial application.  The delegated act will enter into force once it is published in the EU Official … Continue Reading

UK MPs Seek to Designate Iran’s Islamic Revolutionary Guard Corps a Terrorist Organisation

In light of the recent protests in Iran, a UK press report has recently drawn attention to a motion – known as Early Day Motion 483 – filed in October by a Conservative Party MP to designate Iran’s Islamic Revolutionary Guard Corps (“IRGC”) as a terrorist organisation. The motion calls upon the UK Government to … 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
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