Archives: Export Controls & Sanctions

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Upcoming/New CFIUS Filing: Sonaca S.A. and LMI Aerospace

Status:  Upcoming/New Filing   Acquirer:  Sonaca S.A. (Belgium) Acquired:  LMI Aerospace, Inc. (US) Value:  US$14/Share (total value unknown) Industry:  Aerospace   On February 16, 2017, LMI Aerospace, Inc., a St. Louis based global supplier of structural assemblies, kits and components and provider of engineering services to the commercial, business and regional and military aerospace markets, … Continue Reading

South Korea and Japan Announce New Sanctions on North Korea

In response to its recent nuclear and ballistic missile tests, South Korea and Japan have announced that they are imposing new unilateral sanctions on North Korea. The announcements directly follow the UN Security Council’s decision to impose new sanctions on North Korea. Japan is set to impose asset freezes on more people and entities that … Continue Reading

UK’s OFSI Consultation on New Civil Penalties for Sanctions Breaches

The Office of Financial Sanctions Implementation (OFSI) is currently consulting on its draft guidance on monetary penalties for breaches of financial sanctions within the context of new civil powers in the Policing and Crime Act 2017. This guidance sets out how OFSI will assess whether to impose monetary penalties and how those penalties will be … Continue Reading

UK Office of Financial Sanctions Implementation (OFSI) Issues New Guidance on Travel to the UK

OFSI has updated its sanctions guidance in order to include a section on travel to the UK. The new guidance announces that all designated people who are planning to visit the UK, as well as people being funded by a designated person, must hold an appropriate licence to support themselves while in the country that … Continue Reading

OFAC Expands Scope of Authorised Humanitarian Exports to Iran

The Office of Foreign Assets Control (OFAC) has adopted a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), to authorise additional transactions relating to medicine, medical devices and agricultural commodities. The rule expands existing general licences in the ITSR that are adopted under the Trade Sanctions Reform and Export … Continue Reading

UK to Vote on “Magnitsky” Sanctions Against Human Rights Violators

UK Parliamentarians will be voting on the introduction of unilateral sanctions targeting human rights violators, under similar provisions as are in force in the US under the Magnitsky Act. Should the Magnitsky Agreement be passed, it would empower the UK government and private parties to apply to the UK High Court for the UK assets … Continue Reading

Obama Administration Responds to Russian Hacking With Enhanced Cyber-Related Sanctions

On 28 December 2016, the US President issued Executive Order (EO) 13757 to amend a 2015 EO authorising the US Treasury Department’s Office of Foreign Assets Control (OFAC) to impose sanctions for significant malicious cyber-enabled activities. Intended to address alleged Russian tampering in the US elections, EO 13575 expands the scope of the 2015 EO … Continue Reading

EU Extends Russia Sanctions

On 19 December, the European Council extended the application of economic sanctions targeting specific sectors of the Russian economy for a further six months until 31 July 2017. These restrictions were introduced on 31 July 2014 by way of Council Regulation (EU) No 833/2014 “concerning restrictive measures in view of Russia’s actions destabilising the situation in … Continue Reading

BIS Issues Orders Denying Export Privileges to Several Persons

US Department of Commerce’s Bureau of Industry and Security (BIS) issued Orders denying export privileges to Dane Francisco Delgado, Kamran Ashfaq Malik and Robert Luba. BIS also renewed an Order temporarily denying export privileges to Mahan Airways, Pejman Mahmood Kosarayanifard, Mahmoud Amini, Kerman Aviation, Sirjanco Trading LLC, Ali Eslamian, Mahan Air General Trading LLC, Skyco (UK) … Continue Reading

Obama Administration Lifts Embargo of Sudan

On Tuesday, 17 January 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) published in the Federal Register a far-reaching amendment to its Sudanese Sanctions Regulations (SSR), 31 CFR Part 538. While styled as a “general license,” the amendment will have the practical effect of terminating the embargo of Sudan that the US imposed in 1997. … Continue Reading

Intesa Sanpaolo S.p.A. and Its New York Branch Pay a US$235 Million Fine

On 15 December, Intesa Sanpaolo S.p.A. and its New York branch (Intesa) signed a Consent Order with the New York State Department of Financial Services, agreeing to pay a US$235 million penalty and take various remedial actions. Among other things, the Consent Order indicates that Intesa failed to maintain an effective antimoney laundering (AML) and … Continue Reading

New OFAC General License Authorises Transactions for Liquidation of Banco Continental, S.A.

The Office of Foreign Assets Control (OFAC) has issued a new general licence under the Foreign Narcotics Kingpin Sanctions Regulations, 31 C.F.R. part 598, authorising certain transaction relating to the wind-down of the Honduran bank, Banco Continental, S.A. The bank was added to OFAC’s list of Specially Designated Nationals and Blocked Persons in October 2015 in … Continue Reading

EU Amends Its Sanctions on Syria

The European Council has amended its sanctions against Syria in order to allow for the otherwise prohibited purchase or transportation of oil and petroleum products in Syria, where the sole purpose is to provide humanitarian relief or assistance to the Syrian population. The amendments also include a corresponding derogation from the asset freeze and travel … Continue Reading

US Export Controls Workshop: “The ITAR ‘Virus’ EARvolves!” – Stratford-Upon-Avon, UK – 12-14 June 2017

Squire Patton Boggs’ Aerospace, Defense & Government Services Industry Group will co-host the three-day ITAR and EAR workshop sessions with EGADD and Strategic Shipping Company Ltd. This year marks the 10th anniversary of “The ITAR ‘Virus’ EARvolves!” The 2017 conference will take place once again in Stratford-Upon-Avon, UK, from Monday 12 to Wednesday 14 June … Continue Reading

Free Event – SME Briefing on Potential US Business Opportunities – London, UK – 27 January 2017

As part of a broader UK government-led Prosperity Agenda to provide UK companies support to identify and pursue potential export business opportunities, ADS – the premier trade organization for companies in the UK aerospace, defense security and space sectors –  is hosting a complimentary, interactive half-day briefing for SMEs to assist with developing and applying … Continue Reading

Obama Administration Lifts Sanctions on Sudan

On Tuesday, January 17, 2017, the Treasury Department’s Office of Foreign Assets Control (OFAC) will publish in the Federal Register a far-reaching amendment to its Sudanese Sanctions Regulations (SSR), 31 CFR Part 538. While styled as a “general license,” the amendment will have the practical effect of terminating the embargo of Sudan that the US … Continue Reading

7th Annual Advanced ITAR & EAR Compliance Conference & Workshops – Northern Virginia – 8-9 February 2017

Squire Patton Boggs will once again partner with Marcus Evans to host the two-day gathering. The 2017 conference will provide a forum for professionals in the field to discuss with industry and government experts the evolving Export Control Reform, as well as provide assistance with developing compliance strategies to comprehensively address existing regulations and updates. … Continue Reading

DDTC Publishes Final Rule Revising USML Categories VIII and XIX

In the latest steps taken to implement the President’s Export Control Reform initiative, DDTC has published a final rule implementing revisions to Categories VIII (aircraft and related articles) and XIX (gas turbine engines and associated equipment) of the United States Munitions List (USML). Among other things, the rule clarifies the scope of items covered by those … Continue Reading

DDTC and BIS Harmonised Destination Control Statement Rules Go Into Effect

On 15 November 2016, companion rules issued by DDTC and BIS went into effect that adopt a harmonised destination control statement for controlled exports. Exporters must now include the new destination control statement on the commercial invoice for covered items that are exported, retransferred or reexported in tangible form. And, in the case of 9×515 … Continue Reading

BIS Amends EAR to Update Military Arms Embargo Status of Côte d’Ivoire, Liberia, Sri Lanka and Vietnam

US Commerce Department’s Bureau of Industry and Security (BIS) has issued a final rule amending various provisions of the Export Administration Regulations (EAR) to account for changes to controls on exports of arms and related materiel to Côte d’Ivoire, Liberia, Sri Lanka and Vietnam. These actions follow the recent termination of the arms embargos of … Continue Reading

Canadian Parliamentary Committee to Evaluate Canada’s Sanctions Regimes

The Standing Committee on Foreign Affairs of Canada’s Parliament is reviewing Canada’s Freezing Assets of Corrupt Foreign Official Act and Special Economic Measures Act, two crucial pieces of sanctions legislation, including the process for designations, enforcement and monitoring mechanisms, and the impact of the sanctions. The Committee is set to assess the role and effectiveness … Continue Reading