Archives: Export Controls & Sanctions

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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

UK Export Control Organisation (ECO) Revokes Open General Export Licence (OGEL) (International Non- Proliferation Regime Decontrols: Dual-Use Items)

The OGEL (dealing with international non-proliferation regime decontrols: dual-use items) which allowed, subject to certain conditions, the export of specified dual-use (having a civilian and military application) items has been permanently revoked, as it is no longer useful to exporters. If an export can no longer meet the terms and conditions of a particular licence … Continue Reading

UK Export Control Organisation (ECO) Updates and Amends Five Open General Export Licences (OGELs)

The ECO has updated and amended five OGELs following an update to the EU dual-use list, which was published in the EU Official Journal, on 15 November 2016. The updates include changes to the goods schedule of each relevant licence. Of note, Côte d’Ivoire and Liberia have been removed from the list of excluded destinations … Continue Reading

UK Export Control Organisation (ECO) Publishes Latest Version of Consolidated List of Military and Dual-Use Items

On 16 November, the ECO published a new version of its consolidated list of controlled military and dual-use items that require an export licence issued by the ECO. The list includes items such as radioactive sources and torture goods. It also includes dual-use items (that are designed for civilian purposes, which also potentially have a military … Continue Reading

The UK Foreign and Commonwealth Office (FCO) Publishes Its Annual Report for the 2015/2016 Year

In its annual report, the FCO recognises that the UK played an instrumental role in ensuring that the EU remained united in upholding sanctions on Russia, in promoting sanctions on ISIS and in negotiating the Joint Comprehensive Plan of Action (JCPOA) nuclear deal with Iran. According to the report “while there has been good progress … Continue Reading

EU Imposes Asset Freeze Measures on Crimean Members of the Russian Parliament

The EU Council has added six members of the Russian Parliament, all were elected to the State Duma from the Crimea and Sevastopol region of Ukraine in September, to its sanctions adopted with respect to territorial integrity or sovereignty of Ukraine. Regulation (EU) 2016/1955 implementing Regulation 269/2014 and Decision 2016/1961 amending Decision 2014/145/CFSP.… Continue Reading

EU De-Lists Two Syrian Firms After Successful Annulment Applications

The EU Council has de-listed Tri-Ocean Energy and its subsidiary Tri-Ocean Trading from its sanctions against Syria. The de-listings arose from their successful annulment applications in the General Court of the EU in September 2016. In annulling their listings, the Court said that the Council had not properly identified the two entities, and had not … Continue Reading

BIS Updates the EAR to Implement Wassenaar Changes to Encryption Controls and Others

On 20 September 2016, BIS issued a final rule implementing into the Commerce Control List (CCL) and other provisions of the EAR changes made to the Wassenaar Arrangement’s List of Dual-Use Goods and Technologies, adopted at the December 2015 Wassenaar Arrangement plenary meeting. The final rule revises 58 ECCNs in the CCL, adds two new ECCNs and changes eligibility criteria … Continue Reading

OFAC Issues New General License for Temporary Aircraft Exports to Iran

On 29 July 2016, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued a new general license authorising temporary sojourn of certain non-US registered aircraft in Iran. The general license, General License J, applies only to re-exports by non-US persons of fixed-wing civil aircraft that are registered in a country other than the US, Iran or another E:1 country, … Continue Reading

New Rule Harmonises the EAR and ITAR Destination Control Statements

The US Commerce Department’s Bureau of Industry and Security (BIS) and the State Department’s Directorate of Defense Trade Controls (DDTC) each issued companion final rules (see here and here) that will amend the EAR and the ITAR, respectively, to harmonise the destination control statement language provided in both sets of regulations. These actions are the latest in a series taken pursuant … Continue Reading

UN Security Council Calls for Stricter Enforcement of Sanctions Against North Korea

The UN Security Council released a press statement on 6 September condemning the ballistic missile launches conducted by North Korea on 5 September, in direct violation of UN sanctions. The statement further added that members of the Security Council called upon all member states to redouble their efforts to implement fully the measures imposed on North Korea. Back in March … Continue Reading

Theresa May Confirms That Brexit Will Not Affect EU Russian Sanctions

On 1 August, during a phone conversation with President of Ukraine Petro Poroshenko, UK Prime Minister Theresa May confirmed that the position of the UK as regards sanctions against Russia was “unchanged following the UK’s Brexit vote in June”. The Prime Minister further added that sanctions will remain until Russia fully complies with its obligations under the Minsk agreements.… Continue Reading

EU Expands Its Sanctions Against North Korea

The EU sanctions against North Korea have been amended in order to incorporate recent changes to UN sanctions against North Korea and to tighten the restrictions currently in place on North Korean vessels. This update provides for the designation of additional items to which prohibitions on the transfer, procurement and provision of technical assistance apply. Furthermore, the EU has decided … Continue Reading

EU Amends Its List of Restricted Goods Under Its Sanctions Against Iran

The EU has amended Annex 1 (Nuclear Suppliers Group), which includes goods, technology and software, and Annex III (Missile Technology Control Regime) in regard to its anti-nuclear proliferation sanctions against Iran, which designate which items are subject to restrictions under the measures. The amendments include new information about items listed in Annexes I and III in order to enable better identification … Continue Reading

EU Renews Sanctions Over Actions Against Ukraine’s Territorial Integrity

The EU Council has renewed by six months, until 15 March 2017, its restrictive measures targeting actions against Ukraine’s territorial integrity, sovereignty and independence. These restrictive measures consist of asset freezes and travels bans against 146 people and 37 entities. In its statement, the EU Council stated that its assessment of the situation did not justify a change in the … Continue Reading