Last year, we published an update on BIS’s foray into prohibiting EAR99 items for export to Russia and Belarus. We noted (somewhat in jest) that kitchen sinks may one day be added. Well, that day has come. Stainless steel kitchen sinks are officially prohibited for export to Russia and Belarus.Continue Reading Now Including the Kitchen Sink: Expansion of Export Controls on Russia Adds Restrictions on Low-Level Items and Software
On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions risks and implement compliance programs that mitigate those risks. Specifically, the guidance: (i) reaffirms that financial institutions should take a risk-based approach to managing sanctions risks; (ii) highlights key factors that may be relevant in determining that risk-based approach; (iii) encourages the development and deployment of innovative sanctions compliance approaches and technologies to address identified risks; and (iv) encourages developers of instant payment systems to incorporate sanctions compliance considerations as they develop new payment technologies.Continue Reading OFAC Issues Sanctions Compliance Guidance for Instant Payment Systems
After a twelve-year standoff that saw the United States and Europe ratchet up sanctions pressure on Iran, a diplomatic breakthrough has been reached. But robust trade between Iran and the West will not arise immediately, since the end of sanctions is a long way away.
Continue Reading Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?
I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of time for leisure and family. Indeed, most attempts by the country to preserve la vie Française are idealistic efforts to protect what I see as a beautiful way of life (perhaps excluding some of the Académie Française’s more laughable efforts to provide French alternatives to borrowed English words). And some of the country’s biggest companies represent not only the economic engines of France but also embody national pride in global market power.
Continue Reading BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy
The pressure on Russia continues to build. As we previously reported here and here, throughout March, the United States and other Western powers implemented a series of sanctions against individuals and entities deemed to be involved in the political destabilization of Ukraine. Those sanctions were restricted to specific parties, including high ranking Russian and Ukrainian officials and – notably – one Russian bank.
Continue Reading Starving the Bear: The United States Restricts Exports to Russia
By: Scott Maberry and Cheryl Palmeri
Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the face of ongoing uncertainty, the U.S. sanctions program against Iran has continued to develop in a piecemeal sometimes inconsistent fashion.
Since Hassan Rouhani’s election to the Iranian presidency, some U.S. leaders have expressed interest in diplomatic talks with Iran. It is currently unclear whether any such talks will ever occur, or on what terms. In the face of ongoing uncertainty, the U.S. sanctions program against Iran has continued to develop in a piecemeal sometimes inconsistent fashion.
Continue Reading Politics and Consequences: An Update on U.S. Sanctions Against Iran
By: Mark Jensen and Melinda Lewis
June brought a dark milestone in the Syrian civil war as the death toll exceeded 100,000 since the conflict began nearly two years ago. Amid international and domestic pressure to take action against the Syrian government for the continuing escalation of violence against its people, the United States has issued revised sanctions against Syria and announced its intention to provide arms to the Syrian rebels.
Continue Reading The Internet, Food, Petroleum, and World Culture: Recent Updates to the Syria Sanctions
By: Scott Maberry and Matthew Riemer
In the final weeks of May, the U.S. Government engaged in a flurry of Iran sanctions activity, showing a continuing commitment to identifying and penalizing persons who do business with Iran.
Oil, Petrochemical, and Aircraft Industries.
On May 31, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) imposed sanctions on entities and individuals that are part of, or have done business with, Iran’s international procurement and proliferation operations. The targeted entities include branches of the Iranian government (e.g., the Islamic Revolutionary Guard Corps and the Ministry of Defense for Armed Forces Logistics), several Iranian petrochemical companies, and a group of corporations and individuals in Kyrgyzstan, Ukraine, and the United Arab Emirates that lease or sell aircraft to Iranian companies. The sanctions were imposed pursuant to Executive Orders 13,382 (targeting proliferators and supporters of Iran’s weapons of mass destruction) and 13,599 (targeting the government of Iran).
Continue Reading OFAC Continues to Expand the Scope of Iranian Sanctions
On February 6, 2013, the Office of Foreign Assets Control (OFAC) published two guidance documents related to the Iranian sanctions regulations and licenses. The first is Guidance on Humanitarian Assistance and Related Exports to the Iranian People. While the guidance is simply an overview of previously-issued exceptions, the publication is nonetheless an indication of Washington’s efforts to encourage those projects and transactions that benefit the Iranian people directly.
Continue Reading ALERT: Clarifications of the Iranian Sanctions Regulations
By: Scott Maberry and Matthew Riemer
As we reported last month, the Obama administration continues to display a commitment to increasingly tough sanctions against Iran and its trading partners. Over the past few weeks, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) has published new regulations implementing certain sections of the Iran Threat Reduction and Syria Human Rights Act of 2012 (“ITRA”) and various Executive Orders.
Continue Reading Iranian Transactions and Sanctions Regulations Impose New Restrictions on U.S. Business in Iran
By: J. Scott Maberry and Matthew Riemer
In the months since the signing of the Iran Threat Reduction and Syria Human Rights Act (which we will stubbornly continue to refer to here as “ITRA”), the Obama administration has worked to implement tougher sanctions against Iran. Although many of the ITRA regulations are not expected until early November, an Executive Order issued last week marked the beginning of a much stricter era of sanctions pursuant to ITRA, the Iran Sanctions Act of 1996 (ISA), and the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 (CISADA).
Continue Reading Sanctions on Foreign Subsidiaries Implemented Under Iran Threat Reduction Act