Archives: Middle East & North Africa

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UK’s Office of Financial Sanctions Implementation (OFSI) Updates Financial Sanctions

OFSI, part of the HM Treasury, working toward ensuring that financial sanctions are properly implemented and enforced in the UK, has updated numerous financial sanctions that are currently in force. The recent updates are for financial sanctions in the following regions and industries: ISIL/Da’esh and Al-Qaida Organizations Nicaragua Venezuela Central African Republic Ukraine – Sovereignty and Territorial Integrity Syria Libya … Continue Reading

UK Suspends Arms Exports to Turkey

The UK has reportedly suspended the granting of arms export licenses for Turkey in relation to weapons that could potentially be used for military operations in Syria. The suspension follows British ministers ordering a full review into Turkish arms licenses. Liz Truss, the UK’s International Trade Secretary, commented that the International Trade Department “will take into account any developments in the … Continue Reading

EU Decides to Suspend Issuance of License for Arms Export to Turkey

In response to the most recent developments in the Syrian conflict, the Council of the EU decided to halt arms exports licensing to Turkey on October 2019. This decision is based on the criterion that such exports could endanger regional stability. This decision is not a formal sanction, but it is a political declaration to which EU member states will … Continue Reading

OFAC Announces Settlement with DENTSPLY SIRONA INC.

On 6 December 2017, OFAC announced a settlement agreement for US$1,220,400 with DENTSPLY SIRONA INC. (DSI), a US company incorporated in Delaware, the successor in interest to DENTSPLY International Inc. (DII), in connection with 37 violations of the Iranian Transactions and Sanctions Regulations between November 2009 and July 2012. According to the OFAC press release, … Continue Reading

OFAC Announces New Iran-Related Designations

On 4 January 2018, OFAC designated five Iran-based entities “subordinate to a key element of Iran’s ballistic missile program”. OFAC designated these entities pursuant to EO 13382 for being owned or controlled by Iran’s Shahid Bakeri Industrial Group (SBIG). The SBIG is listed in the Annex to EO 13382 and is currently sanctioned by the … Continue Reading

OFAC Announces Settlement Agreements With American Honda Finance Corporation and American International Group, Inc.

On 8 June 2017, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with American Honda Finance Corporation (AHFC), a California company, under which AHFC agreed to pay US$87,255 to settle apparent violations of Cuba sanctions. Separately, on 26 June 2017, OFAC announced a settlement agreement with American International Group, Inc. (AIG), a Delaware company headquartered in New York, … Continue Reading

High Court Rules That UK Arms Sales to Saudi Arabia Are Lawful

On 10 July 2017, the High Court ruled that the export of UK arms and weapons to Saudi Arabia is lawful. The claimant, Campaign Against the Arms Trade (CAAT), had challenged the government’s continued granting of licences for UK arms sales to Saudi Arabia, claiming that the UK was in breach of international humanitarian law. The court held that … Continue Reading

Entry Into Force of Additional Requirements for Licenced Trade With Iran

Additional requirements with regard to the provision of information about end-use and end-use locations that must be complied with in order to receive authorisation for the supply, sale, transfer or use of certain nuclear-related goods to, from or in Iran have been introduced by the EU. Council Regulation (EU) 2017/964 amends Council Regulation (EU) 267/2012 and Council Decision (CFSP) 2017/974 … Continue Reading

EU Updates Listings of Individuals and Entities on Its Sanctions Against Iran

On 23 June 2017, the Council updated the listing information for 14 entities and 23 individuals who are listed on the EU’s anti-nuclear proliferation sanctions against Iran. Council Implementing Regulation (EU) 2017/1124 implements Council Regulation 267/2012 and Council Implementing Decision (CFSP) 2017/1127 implements Council Decision 2010/413/CFSP.… Continue Reading

US Congress Proposes New Iran Sanctions Legislation

On 25 May, the Senate Foreign Relations Committee voted 18-3 to pass S. 722, the Countering Iran’s Destabilizing Activities Act of 2017 (CIDA Act). If enacted, the CIDA Act would create new sanctions against Iran with respect to ballistic missiles and the sale of prohibited arms. The sanctions measures in the CIDA Act are ostensibly … Continue Reading

US Sanctions Persons Connected to Iran’s Ballistic Missile Programme

On 17 May 2017, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated for sanctions seven persons connected to Iran’s ballistic missile programme. Among those targeted by the sanctions are two senior Iranian defense officials, including the Deputy Director for Commerce of Iran’s Defense Industries Organization, Morteza Farasatpour. Farasatpour was responsible for coordinating … Continue Reading

EU General Court Rejects Syria Annulment Application

On 18 May, the General Court of the EU dismissed Rami Makhlouf’s annulment application for his listing on the EU’s restrictive measures targeting Syria. The General Court did so on the basis that he is a member of the Makhlouf family, has close ties to and supports the Assad regime, and is an influential businessman … Continue Reading

Council of the European Union Extends Sanctions Against Syria Until 1 June 2018

On 30 May, the Council adopted Decision 2017/917 that extends the EU’s sanctions against Syria until 1 June 2018, amending Council Decision 2013/255/CFSP. The sanctions impose travel bans and asset freezes against individuals supporting or associated with the Syrian regime or oppression in the country. A total of three ministers of the Syrian government have … 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

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

Trade Talk: Week in Review (6-11 September 2016)

JASTA – Bill Sent to President.  The House voted by voice vote last Friday to advance the Senate-passed JASTA measure to President Obama’s desk for signature into law. Congress acted on a measure that many believe is long-overdue for the victims of the 9/11 attack just ahead of Sunday’s 15th anniversary of the terrorist attack.  … Continue Reading

OFAC Announced Settlement Agreements with Two Companies for Iran and Sudan Sanctions Violations

OFAC announced settlement agreements with two different companies. First, HyperBranch Medical Technology, Inc. agreed to a US$107,691.30 settlement for apparent violations of the Iranian Transactions and Sanctions Regulations. Second, Alcon Laboratories, Inc., Alcon Pharmaceuticals Ltd. and Alcon Management, SA, Settle Potential Civil Liability agreed to a US$7.6 million settlement for apparent violations of the Iranian Transactions and Sanctions Regulations and the … Continue Reading

EU Extends Its Sanctions Against Syria

The sanctions, which are in place until 1 June 2017, include an oil embargo, restrictions on certain investments, freeze of assets of a number of individuals and entities in the EU, export restrictions on equipment and technology that might be used for internal repression and for monitoring or interception of internet or telephone communications. Decision … Continue Reading

Trade Talk – Week in Review (31 May – 3 June)

North Korea – Money Laundering Designation.   Last week, the U.S. Department of the Treasury designated North Korea as a jurisdiction of “primary money-laundering concern” under Section 311 of the USA Patriot Act on Wednesday.  This will allows Washington to further limit North Korea’s access to the U.S. financial system.  Under the new designation, non-U.S. banks … Continue Reading

EP Committee on International Trade Proposes New Position on Iran

On May 23, 2016, the European Parliament (EP) Committee on International Trade engaged in discussions on strategy towards the Islamic Republic of Iran in the wake of the lifting of nuclear-related sanctions against the country, and made several suggestions to the Committee on Foreign Affairs and called for their integration into its motion for a resolution … Continue Reading

UK Export Control Organisation (ECO) Issues Two New Open General Export Licences (OGELs)

Exporters with these licences will now be able to export unpopulated printed circuit boards and wiring harnesses, connectors and fasteners and related components for military and dual-use goods. Exports to several countries, including Russia, Iran, North Korea and China, are not covered. However, both licences will still attract the standard OGEL obligations; exporters must register to use the licences, … Continue Reading

The General Court Dismissed Claim for Damages Relating to the EU’s Targeted Iran Sanctions

The General Court has dismissed a claim for damages brought by Mahmoud Jannatian based on his erroneous listing on the EU’s targeted Iran sanctions.  Mr. Jannatian was originally listed in 2010 because of his role as Deputy Head of the Atomic Energy Organisation of Iran, when he had not held that role since 2007.  As … Continue Reading
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