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
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
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
In response to recent ballistic missile testing activities by the Islamic Republic of Iran, the Trump administration, on 3 February 2017, issued its first economic sanctions, adding 13 individuals and 12 entities to the Office of Foreign Assets Control (OFAC) list of specially designated nationals and blocked persons. The designations were made under counter-proliferation and … Continue Reading
Effective 19 April 2017, a new rule issued by the Department of Commerce, Bureau of Industry and Security (BIS) will require exporters or re-exporters of certain items subject to the Export Administration Regulations (EAR) to obtain and maintain proof of import or export authorization issued by the government of Hong Kong. Under the rule, persons … Continue Reading
In accordance with the 20 January 2017 executive memorandum entitled ‘‘Regulatory Freeze Pending Review,’’ the US Department of Commerce, Bureau of Industry and Security (BIS) has delayed the implementation of changes to the export control classification of software specially designed for the development, production or use of certain oscilloscopes and transient recorders controlled under 3A992.d … Continue Reading
On 9 January 2017, the ECO published new guidance on how to use SPIRE to get an export licence. The guidance sets out the various steps required for completion before exports can use SPIRE. These steps include registering and having available: the EORI number; the export control classification of the items in question; the supporting … Continue Reading
The UK ECO has published a notice that it has updated and amended 16 open licences including 13 open general export licences (OGELs), two open general transshipment licences (OGTLs) and an open general trade control licence (OGTCL). The reason for the change is due to a planned update to the Military List to reflect the … Continue Reading
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
On 27 January 2017, the EU extended until 31 January 2018 its asset freezing measures on individuals, associated persons and entities deemed to be responsible for the misappropriation of state funds in Tunisia. The sanctions, which were first introduced on 31 January 2011, lists 48 people. Implementing Regulation 2017/149 implements Regulation 101/2011 and Decision 2017/153 … Continue Reading
The EU has renewed the entirety of the listings under the EU’s autonomous counter-terrorism sanctions regime that targets individuals and groups who are involved in worldwide terrorism, including Hizballah, Hamas and FARC. Implementing Regulation (EU) 2017/150 implements Regulation 2580/2001 and repeals Implementing Regulation (EU) 2016/1127 and Decision 2017/154 updates Common Position 2001/931/CFSP and repeals Decision … Continue Reading
On 17 January 2017, the EU published a notice addressed to 50 individuals and seven entities designated under its sanctions related to the territorial integrity, sovereignty and independence of Ukraine, stating that it intends to maintain the restrictive measures against these individuals and entities with new statements of reasons. The sanctions target individuals and entities … Continue Reading
Following a recent European Council meeting on 6 February, EU foreign ministers have stated that sanctions against Russia must remain in force until it helps end fighting in eastern Ukraine. Foreign policy chief Federica Mogherini stated that the EU will never recognise Russia’s 2014 annexation of the Crimean Peninsula and insisted that all sides must … Continue Reading
Squire Patton Boggs’ Aerospace, Defense & Government Services Industry Group will co-host the three-day ITAR and EAR workshop sessions, popularly known as “The ITAR Virus EARvolves!“, with EGADD and Strategic Shipping Company Ltd. This year marks the 10th anniversary of these annual workshops, as the ITAR and the EAR continue to evolve. The 2017 conference will … Continue Reading
UPDATE: On 24 February 2017, BIS published a final rule extending until 29 March 2017 the temporary general licence for ZTE Corporation and ZTE Kangxun of China. Under this fourth extension of the ZTE General License, exports, reexports and transfers (in-country) to the entities are subject to the licencing requirements and policies of the Export … Continue Reading
The EU has announced its intention to renew the asset freezing measures imposed on the 48 individuals listed on its sanctions against Tunisia on the grounds of their “responsibility for misappropriating state funds”. At the time of this bulletin, these measures are set to expire on 31 January 2017. The EU’s notices to the listed … Continue Reading
In response to its recent nuclear and ballistic missile tests, South Korea and Japan have announced that they are imposing new unilateral sanctions on North Korea. The announcements directly follow the UN Security Council’s decision to impose new sanctions on North Korea. Japan is set to impose asset freezes on more people and entities that … Continue Reading
With effect from 7 December 2016, HM Treasury’s Office of Financial Sanctions has renewed for 12 months the UK asset freezes which apply to the Popular Front for the Liberation of Palestine (PFLP) and the Popular Front for the Liberation of Palestine – General Command (PFLP-GC), imposed under the Terrorist Asset-Freezing, etc., Act 2010.… Continue Reading
The EU has implemented the UN’s recent sanctions listings in regard to North Korea, and has added 10 entities and 11 people to the list of persons subject to an asset freeze and travel ban. The EU has also removed duplicate entries created by the addition of the new names to its UN-designations annex. Commission … Continue Reading
The Office of Financial Sanctions Implementation (OFSI) is currently consulting on its draft guidance on monetary penalties for breaches of financial sanctions within the context of new civil powers in the Policing and Crime Act 2017. This guidance sets out how OFSI will assess whether to impose monetary penalties and how those penalties will be … Continue Reading
OFSI has updated its sanctions guidance in order to include a section on travel to the UK. The new guidance announces that all designated people who are planning to visit the UK, as well as people being funded by a designated person, must hold an appropriate licence to support themselves while in the country that … Continue Reading
The Office of Foreign Assets Control (OFAC) has adopted a final rule amending the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), to authorise additional transactions relating to medicine, medical devices and agricultural commodities. The rule expands existing general licences in the ITSR that are adopted under the Trade Sanctions Reform and Export … Continue Reading
UK Parliamentarians will be voting on the introduction of unilateral sanctions targeting human rights violators, under similar provisions as are in force in the US under the Magnitsky Act. Should the Magnitsky Agreement be passed, it would empower the UK government and private parties to apply to the UK High Court for the UK assets … Continue Reading
On 28 December 2016, the US President issued Executive Order (EO) 13757 to amend a 2015 EO authorising the US Treasury Department’s Office of Foreign Assets Control (OFAC) to impose sanctions for significant malicious cyber-enabled activities. Intended to address alleged Russian tampering in the US elections, EO 13575 expands the scope of the 2015 EO … Continue Reading
