UPDATE: BIS is extending the public comments deadline on emerging technology export controls from December 19 this year to January 10, 2019, per an unpublished Federal Register notice released on December 13. The proposed rule will officially appear in the Federal Register on December 14. Posted on November 26, 2018 On November 19, 2018, the US … Continue Reading
On October 15, 2018, the Council of the EU adopted new sanctions against people and entities involved in providing financial, technical or material support for or otherwise involved in any business transaction related to proliferation of chemical weapons. In particular, EU sanctions provide for the freezing of assets for sanctioned people/entities.… Continue Reading
In October 2018, the EU decided to amend its list of sanctioned entities and persons in the following countries: Burundi, Guinea and North Korea. Further, the European Commission added new persons to sanctions directed against the ISIL (Da’esh) and Al-Qaida organizations, and removed restrictions imposed on one Iraqi entity. The up-to-date consolidated list of all entities and people subject to EU … Continue Reading
On October 24, 2018, Office of Foreign Assets Control (OFAC) announced that, together with the Department of State, it is extending the Belarus General License 2F’s expiration date. The general license authorizes transactions with certain entities in Belarus pursuant to Executive Order 13405. However, the general license does not authorize the release of blocked property. The expiration date for the general … Continue Reading
The US Department of Commerce, Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to reflect the 2017 changes to the dual-use controls adopted during the 2017 Wassenaar Arrangement Plenary Meetings. As set forth in the October 24, 2018 announcement in the Federal Register, the amendments revise 50 Export Control Classification Numbers (ECCNs) throughout the Commerce Control … Continue Reading
On October 12 and October 19, 2018, Office of Foreign Assets Control (OFAC) extended the expiration date of certain Ukraine-related General Licenses. Specifically, OFAC issued General License 13E and 13F, Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, which extend the deadline for certain transactions with GAZ Group and with RUSAL … Continue Reading
On October 16, 2018, OFAC announced sanctions “against a vast network of businesses providing financial support to the Basij Resistance Force (Basij), a parliamentary force subordinate to Iran’s Revolutionary Guard Corps (IRGC).” According to OFAC, the Basij militia recruits, trains and deploys child soldiers to fight in IRGC conflicts across the region. Bonyad Taavon Basij, an Iran-based network, is comprised of … Continue Reading
On October 5, 2018, the US Department of the Treasury, Office of Foreign Assets Control (OFAC) announced an agreement with JPMorgan Chase Bank, N.A. (JPMC) to settle potential civil liability arising from 87 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, and the Weapons of Mass Destruction Proliferators Sanctions Regulations. According to OFAC, “the transactions … Continue Reading
Congratulations to the National Association of Manufacturers’ Manufacturers’ Compliance Institute for the 2018 Corporate Counsel In-House Innovator Award!… Continue Reading
On September 21, 2018, OFAC extended certain Ukraine-related general licenses. OFAC issued General License No. 13D authorizing certain transactions necessary to divest or transfer debt, equity, or other holdings in listed blocked persons. OFAC also issued General Licenses No. 14A and 16A, which authorize certain activities necessary to the maintenance or wind down of operations or existing contracts with 1) United … Continue Reading
On August 30, 2018, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule titled, “Revisions to the Export Administration Regulations Based on the 2017 Missile Technology Control Regime Plenary Agreements.” This new final rule amending the EAR reflects changes to the Missile Technology Control Regime (MTCR) Annex pursuant to the October 2017 agreement by the … Continue Reading
On August 10, the Council of EU amended its sanctions against South Sudan. This amendment clarifies the scope of limitations imposed on exports of military goods to South Sudan (Council Decision (CFSP) 2018/1125 and Council Regulation (EU) 2018/1116).… Continue Reading
On October 4, 2018, the Directorate of Defense Trade Controls (DDTC) announced in the Federal Register revisions to the ITAR titled, “Regulatory Reform Revisions to the International Traffic in Arms Regulations.” The revisions are in response to comments that the Department of State received. The new rule has removed certain notification requirements from the ITAR, and it removed certain items … Continue Reading
On September 20, 2018, President Trump issued a new CAATSA-related Executive Order (EO) titled, “Authorizing the Implementation of Certain Sanctions Set Forth in the Countering America’s Adversaries Through Sanctions Act” and an accompanying frequently asked question. This EO provides authority to the Secretary of Treasury to take certain actions to implement certain sanctions under the Countering America’s Adversaries Through Sanctions … Continue Reading
The amended EU Blocking Regulation entered into force on August 8. The amendment extended the scope of US sanctions against Iran with which EU citizens or entities must not comply. In addition to the updated EU Blocking Regulation, the European Commission issued: Guidance Note — Questions and Answers: adoption of update of the Blocking Statute Commission Implementing Regulation (EU) … Continue Reading
The European Commission published its draft guidance on the internal effective export control compliance programs. The guidance is subject to public consultation with all interested stakeholders. In order to take part in the consultation, it is necessary to submit a contribution via the on-line survey.… Continue Reading
The Department for International Trade has produced guidance, published on August 23, 2018, informing stakeholders how export controls would be affected if the UK leaves the EU with no deal. The notice explains how export licensing requirements for different groups of items would change and what the UK government proposed to simplify licensing. The export of many controlled items within … Continue Reading
The export control joint unit (ECJU) has amended the Export Control Order 2008 with effect from September 14, 2018. The new Order extends the controls on firearms to include devices capable of being converted to firearms. The ECJU has also updated the consolidated control list of strategic military and dual-use items that require export authorization. The additional devices include the … Continue Reading
In July, following decisions of the Sanctions Committee of the United Nations Security Council, the European Commission lifted the freeze of funds and economic resources sanctions imposed on certain Iraqi entities, including some state owned enterprises (Commission Implementing Regulation (EU) 2018/979, Commission Implementing Regulation (EU) 2018/1025 and Commission Implementing Regulation (EU) 2018/1066).… Continue Reading
The Office of Financial Sanctions Implementation (OFSI), which is part of HM Treasury and works to ensure that financial sanctions are properly implemented and enforced in the UK, has updated a number of financial sanctions currently in force. The recent updates are as follows: Financial sanctions, Libya; Financial sanctions, Ukraine (Sovereignty and Territorial Integrity); Financial sanctions, North Korea (Democratic People’s … Continue Reading
The Trump Administration has added eight Chinese entities and 36 of their subsidiaries to the US Department of Commerce, Bureau of Industry Security’s (BIS) Entity List. Per the final rule published in the Federal Register on August 2, 2018, “[t]he entities that are being added to the Entity List have been determined by the U.S. Government to be acting contrary … Continue Reading
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
On May 8, President Trump announced that the US is withdrawing from the Joint Comprehensive Plan of Action (JCPOA) entered among the P5+1 countries (the US, China, France, Germany, Russia and the UK), the European Union and Iran in July 2015. In our publication, we provide an overview of upcoming changes to US sanctions policy … Continue Reading
