Archives: Export Controls & Sanctions

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CFIUS Filing Update: Sonaca S.A. and LMI Aerospace

Status:  Review   Acquirer:  Sonaca S.A. (Belgium) Acquired:  LMI Aerospace, Inc. (US) Value:  US$14/Share (total value unknown) Industry:  Aerospace   UPDATE:  In relation to the February 16, 2017 Agreement and Plan of Merger between LMI Aerospace, Inc., a Missouri corporation, and Sonaca S.A., a Belgian limited liability company, the parties have announced that:  “On March … Continue Reading

Congress Introduces North Korea and Iran Sanctions Legislation

House lawmakers introduced a new bill, the Korean Interdiction and Modernization of Sanctions Act (H.R. 1644), that would expand existing sanctions targeting trade with the North Korean regime. Further, two new Iran sanctions bills were introduced in the House and Senate – the Iran Ballistic Missiles and International Sanctions Enforcement Act (H.R. 1698) and the … Continue Reading

OFAC Issues General License Authorising Certain Transactions with Soho Panama, S.A.

On 9 March 2017, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 4F, authorising limited transactions with the Panamanian Mall, Soho Panama, S.A, and related entity Westline Enterprises, Inc. Soho Mall Panama was designated for sanctions under the Foreign Narcotics Kingpin Designation Act (21 U.S.C. 1901-1908) in May 2016, in … Continue Reading

BIS Removes ZTE Corp. From Entity List

The US Department of State’s Bureau of Industry and Security (BIS) has removed from the Entity List China’s telecommunications equipment firms Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., known collectively as ZTE. The action follows the agency’s recently announced, record-breaking settlement for US export controls violations, according to which those entities agreed to … Continue Reading

UK Introduces New Monetary and Criminal Penalties for Breach of Financial Sanctions

The new Policing and Crime Act 2017 (the Act), which comes into force in April 2017, provides HM Treasury with enforcement powers to punish breaches of financial sanctions. Under the Policing and Crime Act 2017, HM Treasury has the power to impose monetary penalties if it is satisfied that a person acted in breach of … Continue Reading

BIS Announces Arrest of Ukrainian National and a US$27 Million Settlement With Access USA Shipping, LLC

On 7 March, the Bureau of Industry and Security (BIS) announced the arrest of a Ukrainian national on charges related to the export of military technology to Ukraine. Separately, on 24 March, the BIS announced a US$27 million civil settlement with Access USA Shipping, LLC, a company based in Sarasota, Florida, for alleged export controls violations … Continue Reading

ZTE Corporation Enters Into US$1.19 Billion Settlement

On 7 March, the Departments of Commerce, Justice, and Treasury jointly announced a US$1.19 billion settlement with China-based telecommunications company ZTE Corporation and its subsidiaries and affiliates (together ZTE) for allegedly violating US sanctions and export controls laws. ZTE agreed pay a US$100.9 million civil penalty to the Office of Foreign Assets Control (OFAC); a … Continue Reading

UK Export Control Organisation (ECO) Updates Six Open Licences

The ECO has announced that it has updated and amended six open general export licences (OGELs) in order to reflect the amendments to the Export Control Order 2008, which came into force on 22 February, and the replacement of Schedule 1 to the OGEL for printed circuit boards (PCB) and components for military goods. The … Continue Reading

UK Export Control Organisation (ECO) Amends Its Rules on Capital Punishment Goods

In a notice to exporters from 15 March, the ECO announced that it amended its rules concerning the export of goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, implementing the EU’s new export control rules from November 2016. The list of these goods can be … Continue Reading

UK Export Control Organisation (ECO) Withdraws Iran End-User Concern List

In a notice to exporters from 22 March, the ECO announced that its Iran list has been withdrawn, owing to the substantial lifting of EU sanctions on Iran under the JCPOA nuclear deal signed in 2015. The list was designed to provide information relating to certain entities, companies and organization in Iran for exporters concerned … Continue Reading

Supply Chain Compliance – New French Law on Corporate Duty of Vigilance Law Adopted

On 21 February 2017, the French National Assembly adopted a Corporate Duty of Vigilance Law, which creates a novel corporate supply chain liability, defining a duty of vigilance for parent companies and their subcontractors. The law provides that multinational firms carrying out all or part of their activity on French territory will need to adopt … Continue Reading

EU Amends North Korea Sanctions

With effect from 1 March 2017, the EU has amended its financial sanctions against the Democratic People’s Republic of North Korea to include additional prohibitions. In summary: (1) with effect from 1 March 2017, it is prohibited to open a new bank account held or controlled by a North Korean diplomatic mission, consular post or … Continue Reading

Potential New EU Restrictive Measures on the Democratic Republic of Congo

In a press release published on 6 March 2017, the EU informs the Democratic Republic of Congo that it remains ready to impose new targeted sanctions as a result of the serious human rights violations that have recently occurred in Congo, the refusal of President Joseph Kabila to stand down at the end of his … Continue Reading

EU Extends Ukraine Misappropriation Sanctions

Following its annual review, the EU has renewed its asset freezes relating to individuals who are identified as being responsible for misappropriating Ukrainian state funds until 6 March 2018. These asset freezes were initially introduced in March 2014. Implementing Regulation 2017/374 implements Regulation 208/2014 and Decision 2017/381 amends Decision 2014/119/CFSP.… Continue Reading

EU Extends Asset Freezing Measures and Travel Bans on Individuals and Entities Responsible for Undermining the Territorial Integrity of Ukraine

The EU has extended its asset freezing measures and travel bans on entities and individuals who are involved in undermining or threatening Ukraine’s territorial integrity, sovereignty and independence for a further six months, until 15 September 2017. The EU’s listings on these measures include, to date, 150 people and 37 entities. Implementing Regulation 2017/437 implements … Continue Reading

European Court of Justice (ECJ) Clarifies Sanctions in Response to the Crisis in Ukraine Against Certain Russia Undertakings

In February 2015, the UK Divisional Court referred questions to the ECJ for a preliminary ruling in the course of Rosneft’s judicial review proceedings challenging UK legislation that gives effect to EU sanctions against Russia. The questions referred concerned the interpretation and validity of Council Decision 2014/512/CFSP and Council Regulation (EU) 833/2014. In response to … Continue Reading

EU Renews Its Sanctions Against Bosnia and Herzegovina

The EU Council has renewed its sanctions against Bosnia and Herzegovina until 31 March 2018. The measures include an asset freeze and travel ban on listed individuals and entities believed to be undermining its sovereignty and territorial integrity, posing a serious threat to the Bosnian security situation, or undermining the Dayton/Paris Peace Agreement. Council Decision … Continue Reading

New Era of UK Financial Sanctions Regime – The Policing and Crime Act 2017

On 1 April 2017, HM Treasury implemented a new US-type financial sanctions enforcement framework, The Policing and Crime Act (the Act), that can potentially fine UK and non-UK companies EUR 1 million or more for breaches of financial sanctions. Part 8 of the Act gives the Office of Financial Sanctions Implementation (OFSI), which is part of HM … Continue Reading

OFAC Targets Venezuelan Executive Vice President and Others Under Drug Trafficking Sanctions

On 13 February, the Office of Foreign Assets Control (OFAC) published the names of two individuals and 13 entities designated for blocking sanction under the Kingpin Act for involvement in narcotics trafficking. These included Venezuelan Vice President Tareck Zaidan El Aissami Maddah, and his business partner Samark Jose Lopez Bello, and a network of US and … Continue Reading

EU Removes Five Vessels from its North Korea Sanctions

The EU has removed five vessels from its sanctions against North Korea, implementing a UN decision to de-list them at the end of 2016. The EU had listed these vessels on its sanctions on North Korea for being operated or managed by listed entity Ocean Maritime Management Company. Commission Implementing Regulation 2017/80 amends Council Regulation … Continue Reading

Developments Regarding the Revision of the Dual-Use Export Control Regime

On 28 September 2016, the European Commission published its proposal to “modernise and strengthen” the EU’s dual-use export control regime as laid out by Regulation (EC) No. 428/2009. Now that the commissioner’s proposal has been published, it must be examined by the council and the European Parliament. All three must agree in order to adopt … Continue Reading

EU Removes Entities From Iran Sanctions Lists

The EU has reviewed its nuclear sanctions targeting Iran, as well as judgments of the General Court and the European Court of Justice, annulling listings on those measures and has confirmed that various entities do not appear anymore on the EU’s sanctions lists, they include Moallem Insurance Company, Petropars Operation & Management Company, Petropars Resources … Continue Reading

EU Adds New Information Regarding People Listed on EU Sanctions Against Egypt

The EU Council has issued a notification for the attention of all the individuals listed on the EU’s sanctions who are said to have misappropriated Egyptian state funds, stating that the council holds on its file new elements concerning them and that they may submit a request to the council to obtain the information that … Continue Reading
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