Uncategorized

Subscribe to Uncategorized

On February 24, 2023, the US government announced a range of new export controls, sanctions, and tariffs to coincide with the first anniversary of Russia’s ongoing war against Ukraine. These actions by the US Department of Commerce, Bureau of Industry and Security (BIS), the US Department of the Treasury, Office of Foreign Assets Control (OFAC), the US Department of State, and the White House reflect the continued efforts of the US – in coordination with its allies – to impose costs on Russia for the war.

Each successive round of US export controls and sanctions presents new compliance challenges, against the backdrop of heightened enforcement risk resulting from aggressive, well-coordinated US government actions. US and non-US entities and individuals who engage in transactions related to Russia or Belarus should pay close attention to this complex and evolving regulatory framework. Additionally, entities and individuals exporting to Iran should take note of the expanded scope of the US Export Administration Regulations (EAR) under a new Iran Foreign Direct Product (FDP) Rule.…

Continue Reading US Imposes Additional Export Controls, Sanctions, and Tariffs targeting Russia, Belarus, and Iran On First Anniversary of Russia’s War Against Ukraine

On February 9, 2023, the UK announced the designation of seven individuals said to be part of a Russia-based cybercrime gang under the UK’s thematic cyber sanctions regime pursuant to The Cyber (Sanctions) (EU Exit) Regulations 2020.  The designations were coordinated with the US.  Concurrently, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”), in partnership with other HM Government  (“HMG”) organisations, published guidance on sanctions and ransomware, which addresses the impact of ransomware payments, cyber resilience, and HMG’s approach to enforcement of financial sanctions breaches related to ransomware attacks.…

Continue Reading UK Sanctions Russian Cybercrime Gang and Issues New Guidance on Sanctions and Ransomware

On April 21, 2021, the EU General Court rendered a judgement on an appeal against the retention of Aisha Qaddafi, the daughter of the late Colonel Muammar Qaddafi, on EU sanctions lists. The judgment confirms the case law according to which the EU Council may, in certain cases, have to produce additional proof to justify the listing of a person, even where this person has been previously designated in a Resolution of the UN Security Council.

Aisha Qaddafi was first listed by the EU in March 2011, shortly after her designation by the UN Security Council. Since then, the EU sanctions lists have been updated several times without any amendments to the listing of Ms. Qaddafi. The contested acts by which the listing of Ms. Qaddafi was maintained and which were adopted in 2017 and 2020, did not mention any new factors other those which had been put forward for the initial listing of her name in 2011. The stated reason for listing her under EU sanctions was the simple fact that she had been designated by the UN Security Council in 2011.…

Continue Reading EU General Court lifts sanctions against daughter of Muammar Qaddafi

On September 17, 2020 the EU Court of Justice (“the Court”) rendered a judgement, by which it upheld the General Court’s decision dismissing an action brought by members of the Rosneft group. The judgement concerned the validity of some of the EU’s sanctions imposed on Russian oil companies in the context of the Ukraine…

On June 5, three Steptoe lawyers will participate in the ABA’s 2018 Drone Law Conference.  Steptoe associate Rebecca Lipe will moderate and partner Dane Jaques will participate on a panel titled “Safety Challenges & Accident Reporting.” The panel will focus on the NTSB process from investigation through litigation and potential pitfalls related to Unmanned aircraft …

Commerce Secretary Wilbur Ross announced on the evening of May 23 that he would begin a Section 232 investigation into the national security implications of automobile imports. According to a Department of Commerce (DOC) statement, the investigation will “determine whether imports of automobiles, including SUVs, vans, light trucks, and automotive parts into the United…

On Thursday, May 31 at 11:00 AM EST, Anthony Rapa will present “Russia Sanctions—Where Things Stand”, a webinar hosted by Federal Publications.  As described on the Federal Publications website:

The United States has imposed a broad range of sanctions targeting Russia, based on factors such as the annexation of Crimea, Russia’s incursion into eastern Ukraine…

The Office of the US Trade Representative (USTR) published on April 3, 2018 a proposed list of products imported from China to target with an additional 25% tariff. These tariffs have been proposed in response to USTR’s findings in an investigation conducted under Section 301 of the Trade Act of 1974 (Section 301) and would…

On March 1, House Democrats introduced the Buy America 2.0 Act (Buy America 2.0), H.R. 5137, continuing the recent emphasis on imposing “Buy America” requirements on federally funded projects.  Other related actions include President Trump’s April 2018 Executive Order (EO) 13788, Buy American – Hire American and the BuyAmerican.gov Act of 2018 (S.2284). Buy…