Tag Archives: exports

New Business Opportunities in Iran! But Who Will Be Your Banker? Non-U.S. Banks Hesitant to Process Lawful Iran Transactions…and for Good Reason

Highlights: Sanctions relief presents new business opportunities with Iran Most U.S. companies are still prohibited from Iran business, but the U.S. government is encouraging lawful business by non-U.S. companies The line between permitted and prohibited financial transactions by non-U.S. banks is not clear Careful advice of counsel is critical… Continue Reading

The Day of North Korea Sanctions: the UN Imposes the Toughest North Korea Sanctions Yet While OFAC and State Designate More North Korean Entities

After weeks of negotiations and a Putin-backed delay, the UN Security Council unanimously adopted resolution 2270 on March 2, 2016, imposing new sanctions against North Korea. According to U.S. Secretary of State John Kerry, the resolution imposes the strongest set of UN sanctions in over two decades. This article provides a summary of the new … Continue Reading

State Department Issues Nuts and Bolts Guidance on Libya

By: Thad McBride On May 10, 2013, the U.S. State Department issued unusually practical guidance (the Guidance) on exporting to Libya.  The Guidance, which even has a practical name – “Direct Commercial Sales of Defense Articles and Services to Libya” – is available here. For many years, the United States has imposed extensive restrictions on exports of defense articles to Libya.  Since February 2011, unilateral U.S. restrictions on such exports have been buttressed by an arms embargo imposed on the country by the United Nations.  Under part 126 of the U.S. International Traffic in Arms Regulations (ITAR), UN arms embargoes essentially have direct effect under U.S. law.  With respect to Libya, this means that section 126.1(k) of the ITAR tracks the restrictions that the United Nations has imposed on Libya.… Continue Reading

Census Changes Foreign Trade Regulations: New Filing Requirements

By:  Thad McBride and Matthew Riemer On Thursday, March 14, the Census Bureau published a final rule (available here) implementing changes to the Foreign Trade Regulations (FTR), 15 C.F.R. Part 30.  The final rule includes long-awaited revisions to the post-departure filing program commonly referred to as Option 4.  Census is also requiring mandatory filing of export information through the Automated Export System (AES) or through AESDirect for all shipments of temporary exports.  The final rule also implements remedial changes to the FTR to improve clarity and to correct errors.… Continue Reading
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