Export Controls & Sanctions

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UK Export Control Unit (ECJU) Amends Export Control Order 2008

The ECJU has amended the Export Control Order 2008 through the implementation of Directive (EU) 2019/514. The Export Control (Amendment) Order 2019, which came into force on June 30, 2019, amends the list of defense-related products. The changes correspond to updates made to the European Military List. In addition, updates were made to remove Eritrea from the list of countries embargoed … 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

EU Publishes Regulation Concerning Restrictive Measures in Nicaragua

On October 14, 2019, the EU published a regulation concerning restrictive measures in view of the situation in Nicaragua. The EU sanctions target persons and entities responsible for human rights violations or abuses, the repression of civil society and democratic opposition in Nicaragua, as well as persons and entities whose actions, policies or activities otherwise undermine democracy and the rule of … Continue Reading

US Wins Award in Airbus Subsidies Case

In October, the US Trade Representative (USTR) announced that the US had won the largest arbitration award in the World Trade Organization’s (WTO) history, in its dispute with the EU over illegal subsidies to Airbus. The decision awarded US$7.5 billion, which is nearly twice the next largest award. The arbitrator calculated the amount of the award based on WTO findings … Continue Reading

US Department of State Imposes Visa Restrictions on Chinese Officials for Repression in Xinjiang

On October 8, 2019, the Secretary of State announced visa restrictions on Chinese government and Communist Party officials believed to be responsible for, or complicit in, the detention or abuse of Uighurs, Kazakhs or other members of Muslim minority groups in Xinjiang, China. Family members of named persons may also be subject to these restrictions. The visa restrictions support the Department … Continue Reading

OFAC Enters Settlement With The General Electric Company for Violations of Cuba Sanctions

In early October, OFAC announced a US$2,718,581 settlement with The General Electric Company (GE) of Boston, Massachusetts. GE, on behalf of three GE subsidiaries, Getsco Technical Services Inc., Bentley Nevada and GE Betz (collectively, the “GE Companies”), agreed to settle its potential civil liability for 289 alleged violations of the Cuban Assets Control Regulations (CACR). Specifically, between December 2010 and February … Continue Reading

Trump Administration Authorizes Sanctions on Turkey

Responding to Turkey’s actions in Syria, President Trump issued an Executive Order (EO) blocking property and suspending entry of certain persons contributing to the situation in Syria. Pursuant to the EO, OFAC added three Turkish government officials and two Turkish government agencies, the Ministry of National Defence and the Ministry of Energy and Natural Resources, to the Specially Designated Nationals (SDN) … Continue Reading

US Office of Foreign Assets Control (OFAC) Temporarily Extends Belarus-related General License

On October 22, 2019, OFAC issued General License No. 2G – General License with Respect to Entities Blocked Pursuant to Executive Order 13405, extending the expiration date of the general license to April 26, 2021. General License No. 2G replaces General License No. 2F and authorizes transactions with blocked entities by Belerusian Oil Trade House, Belneftekhim,  Belneftekhim USA, Inc., Belshina OAO, … Continue Reading

US Department of Commerce Adds 28 Chinese Organizations to Its Entity List

In response to ongoing human rights violations, BIS announced that it would add 28 Chinese governmental and commercial organizations to the Entity List for engaging in or enabling activities contrary to the foreign policy interests of the US. This action targets those entities implicated in human rights violations and abuses in China’s campaign targeting Uighurs and other predominantly Muslim ethnic minorities … Continue Reading

OFAC Implements Sanctions on Nicaragua

On September 4, 2019, the US Department of the Treasury’s Office of  Foreign Assets Control (OFAC) published in the Federal Register a new final rule on the Nicaragua Sanctions Regulations, 31 C.F.R. Part 582 (Nicaragua Regulations), which implement Executive Order (EO) 13851 of November 27, 2018, “Blocking Property of Certain Persons Contributing to the Situation in Nicaragua”. The Nicaragua Regulations mirror the substance … Continue Reading

Update: Turkey’s Actions Spur Transatlantic Sanctions Response

The Trump Administration issued an Executive Order (EO) on October 14, 2019, that authorized US Department of the Treasury (Treasury) and US Department of State to impose sanctions on various Turkish individuals and entities involved in the conflict in Northern Syria. The same day that the EO was issued, Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and two entities as … Continue Reading

Advice for Chinese Companies: How to Cope with Strengthened US Export Controls and CFIUS – Seminars in Shanghai and Beijing – October 2019

Keep US Open to Chinese Business: 维持一个对华企业开放的美国: How to Cope With Strengthened US Export Controls and CFIUS 应对日趋严格的美国出口管制和CFIUS审查的实务指南 Friday, October 11, 2019 – Shanghai (2019 年10月11日,周五 – 上海) Tuesday, October 15, 2019 – Beijing (2019 年10月15日,周二 – 北京)… Continue Reading

Training Opportunity: Discussion on Tech-centric Anticorruption and Sanctions Compliance – 20 September, London

20 September 2019  9:30 a.m. – 2:30 p.m. BST Register through techUK (favorable registration rate available to members) Register through eventbrite (event open to non-techUK members) Joining forces with techUK, Content Enablers and Dun & Bradstreet, our International Trade Practice is hosting a timely discussion on tailored approaches for UK technology businesses to effectively navigate … Continue Reading

Recent Cuba Travel-related Settlements With OFAC Demonstrate Importance of Robust Sanctions Compliance Program

On June 13, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) announced settlements with three travel companies – Expedia Group, Inc. (Expedia), Hotelbeds USA, Inc. (Hotelbeds USA) and Cubasphere Inc. (Cubasphere) – for their alleged involvement in booking travel to Cuba or arranging trips for Cuban nationals between 2011 and 2014.… Continue Reading

US Adds Five Chinese Companies to the Department of Commerce Entity List

On June 24, 2019, the US Department of Commerce, Bureau of Industry and Security (BIS) published in the Federal Register a Final Rule designating five entities, all located in China, to the Entity List. The five entities are: Chengdu Haiguang Integrated Circuit – aliases include Hygon and Chengdu Haiguang Jincheng Dianlu Sheji Chengdu Haiguang Microelectronics Technology – aliases include HMC … Continue Reading

Training Material Available: Export Controls and Technology Transfers Conference – June 19-20, 2019 | Washington DC

George Grammas’s presentation on “Strengthening Trade Compliance in Line with Recent Legislative Developments and Impacts to Controls via an Examination of Extraterritorial Applications, Order of Review, and Classification” is now available in our Learning Center, in which you can also find other training resources and information.… Continue Reading
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