Archives: Export Controls & Sanctions

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Changes to the US’ Iran Policy and Additional Non-Nuclear Iran-related Designations

On 13 October, President Trump announced the results of his administration’s review of the US’ Iran policy, indicating at the same time that he would not “certify” to Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA) agreement. Since President Trump took office, he has “certified” to Iran’s compliance twice, so this is the first time that he did … Continue Reading

President Imposes New Economic Sanctions Against North Korea

On 20 September, President Trump issued an Executive Order (EO) authorising broad new economic sanctions against North Korea, by targeting those dealing with the country. The Order, EO 13810, adds to the existing US embargo of North Korea by authorising the US Treasury’s Office of Foreign Assets Control (OFAC) to impose blocking sanctions against any person found to be participating … Continue Reading

Trump Administration Permanently Lifts Sudan Sanctions

On 6 October, the Trump administration announced that it would permanently revoke economic sanctions against Sudan, effective 12 October 2017. The State Department published this decision in the Federal Register, 82 Fed. Reg. 47287, on 11 October 2017. This decision means that US companies can invest in Sudan and export their products and services to Sudan, subject to compliance with … Continue Reading

UK Implements EU Sanctions on Mali

On 17 October, the UK published the Republic of Mali (European Union Financial Sanctions) Regulations 2017 (SI 2017/972). These follow Council Regulation (EU) 2017/1770 of 28 September 2017, which imposed “travel restrictions and the freezing of funds and economic resources of certain of persons designated by the United Nations Security Council as responsible for or complicit in, or having … Continue Reading

EU Renews Sanctions on Guinea and Moldova

On 23 October, the EU renewed existing sanctions on Guinea until 27 October 2018, and those on Moldova until 31 October 2018. It also published a notice to those on the Guinea list renewing their inclusion in the Annex to Council Decision 2010/638/CFSP and Annex II to Council Regulation (EU) No 1284/2009, explaining that they may request that this be … Continue Reading

European Commission Initiates Anti-dumping Investigation Against Imports of Electric Bicycles From China

On 20 October, the European Commission initiated the new anti-dumping investigation against imports of electric bicycles from China. The product concerned is cycles with pedal assistance and auxiliary electric motors. The complaint was lodged by the European Bicycle Manufactures Association, which claims that the imports of electric bicycles from China undercut and undersell the EU industry by substantial margins.… Continue Reading

EU Considers Further Sanctions on Myanmar/Burma

On 16 October, with respect to Myanmar/Burma, the Council of the EU issued a statement in which it stated that “the Council may consider additional measures if the situation does not improve but also stands ready to respond accordingly to positive developments”. In April, the EU renewed existing sanctions on Myanmar/Burma imposing an embargo on goods that might be used … Continue Reading

EU Issues Statement in Support of JCPOA

On 16 October, in the wake of US President Trump’s decision not to certify Iran’s compliance with the Joint Comprehensive Plan of Action (JCPOA), the EU issued a statement saying that “it is committed to the continued full and effective implementation of all parts of the JCPOA”. Furthermore, that “the European Union considers President Trump’s decision not to certify Iran’s … Continue Reading

EU Adopts New Sanctions on North Korea

On 16 October, the Foreign Affairs Council adopted new EU autonomous measures reinforcing the sanctions on North Korea imposed by the UN Security Council, effective immediately. They include a total ban on EU investment in North Korea across all sectors, whereas previously the ban related to certain sectors, such as the arms industry and chemical industries. Also, there is a … Continue Reading

EU Institutions Agree on New Methodology for Anti-dumping Investigations

On 4 October, two main law-making bodies of the EU, the European Parliament and the Council, agreed on the reform of the EU anti-dumping mechanism. The new reform should enter into force at the beginning of 2018. According to new rules, the European Commission will calculate the normal value for dumped goods imported from China, giving priorities to actual prices … Continue Reading

EU Reduces Tariff on Imports from Ukraine

As of 1 October, the EU opened its market for some agriculture and industrial goods produced in Ukraine. The new EU Regulation on autonomous tariff measures grants certain benefits for Ukrainian importers. For instance, it waives customs duties for Ukrainian fertilizers, aluminum products or consumer electronics, also giving advantages to EU entrepreneurs that trade or purchase goods or raw materials … Continue Reading

Commission Updates EU Control List of Dual-List Items

On 26 September, the Commission adopted the annual Delegated Regulation updating the EU dual-use export control list in Annex I to Regulation (EC) No 428/2009. The update aligns the list with the decisions taken within the framework of the international non-proliferation regimes and export control arrangements in 2016. The changes include updated acronyms and abbreviations, new definitions for certain terms … Continue Reading

EU Renews Sanctions on Burundi

On 23 September, the European Council extended EU sanctions against Burundi until 31 October 2018. The restrictive measures include a travel ban and asset freeze on four persons whose activities were judged to be undermining democracy and stifling attempts to reach a political solution to the situation in Burundi. The official Council press release is available here.… Continue Reading

Save-the-Date: US Export Controls Workshop – “The ITAR ‘Virus’ Continues to EARvolve!” – Stratford-Upon-Avon, UK – July 23-25, 2018

Our Aerospace & Defense Group is pleased to partner once again with EGADD and Strategic Shipping Company Ltd to host the upcoming “The ITAR ‘Virus’ Continues to EARvolve!” US Export Controls Workshop in Stratford-Upon-Avon, UK, Monday, July 23 – Wednesday, July 25, 2018. 2018 welcomes the 11th anniversary of the workshop.… Continue Reading

Trump Administration Permanently Lifts Sudan Sanctions

  Sudan Sanctions In 1997, the US imposed a comprehensive trade and investment embargo against Sudan. In January 2017, i.e., in the closing days of the Obama Administration, President Obama announced a six-month suspension of US economic sanctions, citing ongoing dialogue with the Sudanese government and the government’s progress in achieving milestones agreed upon in those negotiations. Specifically, the Obama Administration … Continue Reading

European Commission Considers a CFIUS-like Framework for Screening Foreign Investments

On September 13, 2017, the European Commission published the draft of the EU regulation establishing a common European framework for the review of incoming foreign direct investment (FDI), akin to the process in the US administered by Committee on Foreign Investment in the US (CFIUS).… 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

UN Adopts New Sanctions Against North Korean Offcials and Entities

On 2 June 2017, the UN Security Council adopted new sanctions targeting 18 North Korean officials and entities as a result of North Korea’s recent ballistic missile tests. Under these sanctions, entities and people are subject to an asset freeze and travel ban in all UN countries. The EU’s implementing measures are Commission Regulation 2017/970, which amends Council Regulation 329/2007 … Continue Reading

US Treasury Department Proposes Financial Sanctions Against Chinese Bank to Address North Korea Concerns

On 29 June 2017, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule that would designate China’s Bank of Dandong to be a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act. The measure responds to findings that the bank used the US financial system to facilitate millions of dollars … Continue Reading
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