Archives: Economic Sanctions

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EU Promotes Export Controls and Sanctions Compliance Programs

The European Commission (the Commission) recently issued draft guidelines on the core elements that European industry should take into account when implementing internal export controls and sanctions compliance programs.  The guidance – which is legally non-binding – will be finalized upon the results of a public consultation providing the opportunity for EU exporters to comment … Continue Reading

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 Adds Additional Names to SDN List under Venezuela Program

On September 25, 2018, OFAC added six individuals, three entities, and an aircraft to the SDN list (link to press release here).  These designations appear to be motivated by a continued effort to pressure the Maduro government to change its policies.  The press release notes that, “By the end of 2018, hyperinflation in Venezuela is … Continue Reading

Trump Administration Sanctions Key Chinese Military Entity under Russia Authorities

On September 20, 2018, the State Department announced sanctions on China’s Equipment Development Department (EDD) (formerly known as the General Armaments Department (GAD)) and its director, Li Shangfu, for engaging in significant transactions with Russia’s Rosoboronexport for the delivery to China of Su-35 combat aircraft in 2017 and equipment for S-400 surface-to-air missile systems in … Continue Reading

US State Department Announces New Russia Sanctions

On August 8, 2018, the US State Department announced that it would be imposing new sanctions on Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).  The new sanctions are in response to a determination by the US government that the Russian government was behind the recent … Continue Reading

Certain Iran Sanctions Reimposed after 90-Day “Wind-Down” Period Ends

President Trump issued an Executive Order today re-imposing and, in some cases, expanding sanctions on Iran that had been lifted under the 2016 nuclear deal (the “JCPOA”), as today marked the end of the first “wind-down” period of 90 days following the President’s May 8 announcement that the US would no longer honor its sanctions … Continue Reading

U.S. Rejects European Requests for Exemptions to Iran Sanctions

Since President Trump’s announcement, on May 8, that the United States would withdrawal from the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose previously lifted sanctions against Iran, the remaining JCPOA signatories have been scrambling to save the agreement. On June 4, officials from the UK, Germany, France, and the EU sent a letter to … 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

President Trump Issues Venezuela-Related Executive Order

On May 21, 2018, President Trump issued a new executive order prohibiting certain transactions benefitting the government of Venezuela.  The order prohibits all transactions related to, provision of financing for, and other dealings in: (i) the purchase of any debt owed to the Government of Venezuela, including accounts receivable, (ii) any debt owed to the … Continue Reading

In-Depth Advisory on President’s Announcement of Withdrawal From JCPOA and Reimposition of Nuclear-Based Sanctions on Iran

In addition to our previous updates, Steptoe recently published an in-depth advisory on President Trump’s May 8, 2018 decision to withdraw the United States from the Joint Comprehensive Plan of Action (JCPOA). The JCPOA is an agreement reached in July 2015 between Iran, the United States, the United Kingdom, France, China, Russia, and Germany in … Continue Reading

Russia Sanctions: General Licenses, Deadlines, Russian Counter-Measures– What’s the Latest?

As the world turns… There have been several key developments recently in the Russia sanctions context: Issuance of General License 15.  This general license, issued May 22, authorizes maintenance and winding down of pre-April 6 business with GAZ Group and its subsidiaries through October 23.  The authorization is similar in scope to General License 14, issued on … Continue Reading

Russian State Duma Proposes to Criminalize Compliance with US and EU Sanctions and Adopts Retaliatory Measures

On May 14, a cross-party group of Russian lawmakers at the Russian State Duma, the lower house of the Federal Assembly of Russia, introduced an amendment to the Criminal Code of the Russian Federation to create a new offense that would criminalize compliance with US and EU sanctions on Russian soil.  On May 15, the … Continue Reading

OFAC Issues General License Extending Authorization for Dealings with GAZ Group

Yesterday, OFAC issued General License No. 15 under the Ukraine-Related Sanctions Regulations (31 C.F.R. Part 589), authorizing the maintenance or wind-down of pre-April 6 contracts with GAZ Group and its subsidiaries through October 23, 2018.  Previously, such activity with GAZ Group was permitted only through June 5, 2018 as per General License No. 12B (which … Continue Reading

OFAC Eases Maintenance/Wind-Down and Divestment Restrictions in New General Licenses

On May 1, OFAC issued two amended general licenses under the Ukraine-Related Sanctions Regulations (URSR). General License No. 12B, superseding General License No. 12A, authorizes additional activities necessary to the maintenance and winding down of operations or existing contracts. General License No. 13A, superseding General License No. 13, authorizes certain additional transactions necessary to divest … Continue Reading

President Trump Withdraws United States from Iran Nuclear Agreement

Today, President Trump announced “that the United States will withdraw from the Iran nuclear deal” and issued a National Security Presidential Memorandum (NSPM) “to begin reinstating” the “highest level” of economic sanctions on Iran.  Today’s action sets in motion the termination of all or nearly all of the sanctions relief offered by the United States … Continue Reading

OFAC Renews Belarus Sanctions Relief

On April 27, 2018, the U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) issued a general license extending sanctions relief that 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 entities that they own 50% or more. The … Continue Reading

OFAC Issues General License Extending Maintenance / Wind-Down Period for Rusal Dealings

On Monday, OFAC issued General License No. 14 under the Ukraine-Related Sanctions Regulations (URSR), authorizing the maintenance or winding down of business with United Company Rusal plc (Rusal) through October 23, 2018.  The imposition of sanctions on Rusal, which OFAC listed as a Specially Designated National (SDN) on April 6, had roiled the global aluminum market and … Continue Reading

New Sanctions Against Russian Oligarchs, Officials, and Companies May Have Significant Impact

Following up on our earlier blog post, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new blocking sanctions on April 6, 2018 against seven Russian oligarchs, 12 entities owned or controlled by those oligarchs, 17 senior Russian government officials, a Russian weapons trading company, and a banking subsidiary owned by … Continue Reading

OFAC Sanctions Russian Oligarchs and Major Russian Companies

Today, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) designated several Russian individuals and companies as Specially Designated Nationals (SDNs).  Specifically, in response to what Treasury Secretary Steven Mnuchin described as Russia’s “malign activity”, OFAC indicated that it sanctioned seven Russian oligarchs and 12 companies they own or control, 17 senior Russian … Continue Reading

President Imposes First US Economic Sanctions Against Venezuelan Digital Currency

On March 19, President Trump issued Executive Order 13827, which imposes the first US sanctions against a virtual currency – namely, a digital currency known as the “petro” that has been issued by the Government of Venezuela (GOV). Specifically, the executive order prohibits “all transactions related to, provision of financing for, and other dealings in, by … Continue Reading

Newly Introduced Sanctions Bill Targets IRGC

On March 1, House Foreign Affairs Committee Chairman Ed Royce (R-CA) and the committee’s ranking Democrat, Eliot Engel (D-NY), introduced bipartisan legislation targeting Iran’s Islamic Revolutionary Guard Corps (“IRGC”), a branch of Iran’s armed forces considered responsible for much of Iran’s international terrorism and domestic repression.  The new bill, known as the Iranian Revolutionary Guard … Continue Reading

Russia Sanctions: Amended OFAC Directive 4 Effective Today

Today is the effective date of the expanded sanctions set out in Directive 4 under the U.S. Russia sanctions program, as amended by the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) on October 31, 2017.  The amendment implemented Section 223 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), signed into law … Continue Reading

What if President Trump Refuses to Renew Iran Sanctions Waivers?

Last week, while reluctantly renewing waivers of statutory sanctions against Iran, President Trump issued an ultimatum: Either the United States’ European allies negotiate a “supplemental agreement” that strengthens the Joint Comprehensive Plan of Action (JCPOA) nuclear agreement and targets Iran’s ballistic missile program, or the United States will no longer waive sanctions against Iran.  The President’s … Continue Reading
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