Archives: Iran

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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

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

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

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

Notice to Remaining Individuals Subject to Human Right Sanctions in Iran

The EU sanctions relating to human rights concerns in Iran did not fall under the Joint Comprehensive Plan of Action (JCPOA), and so were not part of the group of sanctions lifted in January this year. As such, the EU Council have now released a notice informing the 20 individuals that are subject to human … Continue Reading

The Grand Chamber of the European Court of Justice Upheld the General Court’s Decision on the National Iranian Oil Company

The National Iranian Oil Company (NIOC) has lost an appeal to the Grand Chamber of the European Court of Justice to set aside the General Court’s decision not to annul its sanctions listing.  NIOC was originally added to the Iranian sanctions list in 2012, on the premise it is a state owned entity that provides … Continue Reading

EU Powers Sent Letter to UNSC over Iranian Missile Launches

The UK, along with France, Germany and the US have criticised Iran for its recent missiles tests. In a joint letter to Spain’s UN ambassador and UN chief Ban Ki-moon, the group of countries accused Iran of defying a UN Security Council resolution by launching nuclear-capable missiles. The tests have reignited discussions over EU and US sanctions. The situation … Continue Reading

US and EU Implement Iran Sanctions Obligations Under the JCPOA

Saturday, 16 January 2016, marked Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) between the E3/EU+3 (China, France, Germany, the Russian Federation, UK and US, in conjunction with the High Representative of the European Union for Foreign Affairs and Security Policy) and the Islamic Republic of Iran (Iran). On Implementation Day, the International … Continue Reading

Trade Talk – Week in Review (18-22 January 2016)

The Senate was in session last week, while the House of Representatives (“the House”) remained in recess in observance of the Martin Luther King holiday.  Implementation Day of the Joint Comprehensive Plan of Action (JCPOA) with Iran took effect, as did a prisoner swap last week.  Washington’s attention then quickly shifted to an impending historic … Continue Reading

Trade Talk – Week in Review (4-8 January 2016)

Glove in a boxThe House of Representatives reconvened last Tuesday in Washington.  The Senate is in session today.  President Barack Obama will address a joint session of Congress tomorrow when he gives the annual State of the Union. Iran – Obama Administration Stays the Course.  Lawmakers continue to advocate for new sanctions to be imposed on Iran for … Continue Reading

Multiple Individuals Faced Criminal Penalties for Export Violations

The US Department of Justice (DOJ) announced the convictions of Alexander Posobilov, Shavkat Abdullaev and Anastasia Diatlova for conspiring to export, and illegally exporting, controlled microelectronics to Russia in violation of the International Emergency Economic Powers Act (IEEPA) and the Arms Export Control Act (AECA). Separately, the DOJ also announced the sentencing of Mozaffar Khazaee … Continue Reading

Iran Nuclear Deal Update

Adoption Day of the JCPOA occurred on 18 October 2015. On Adoption Day, the US took a number of steps to prepare for the implementation of its JCPOA obligations, including the US State Department’s issuance of waivers of certain statutory sanctions contingent on the JCPOA’s Implementation Day. Further information on Adoption Day can be found … Continue Reading

Iran

On 18 October 2015, the Parties to the Joint Comprehensive Plan of Action (JCPOA) welcomed the Adoption Day of Agreement  related to the Iranian nuclear programme, where Iran will now start implementing all of its nuclear-related commitments.  Meanwhile, the EU adopted the legislative framework to lift all of its nuclear-related economic and financial sanctions, which … Continue Reading
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