The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued four new Frequently Asked Questions (FAQs) related to Executive Order (E.O.) 13902, “Imposing Sanctions With Respect to Additional Sectors of Iran.” The FAQs address the manufacture of medicines, medical equipment and sanitation products in Iran, the scope of sectors targeted
Scott E. Diamond**
Scott is a senior policy advisor with more than 25 years' experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.
**Not licensed to practice law.
OFAC Issues Syria-Related Regulations to Implement 2019 Executive Order Responding to Turkey’s Military Actions
On June 3, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued new regulations under 31 CFR Part 569 to implement Executive Order (E.O.) 13894 issued by President Trump on October 14, 2019. The President issued E.O. 13894 in response to the situation in and around Syria, in particular, the military…
USTR Initiates Section 301 Digital Services Tax Investigations on EU, India and Others
The Office of the United States Trade Representative has announced it will begin investigations under Section 301 of the 1974 Trade Act into digital services taxes that have been adopted or are being considered by Austria, Brazil, the Czech Republic, the European Union, India, Indonesia, Italy, Spain, Turkey, and the United Kingdom. According to the…
Commerce Initiates Section 232 National Security Investigation into Vanadium Imports
On June 2, 2020, Secretary Wilbur Ross announced that the Department of Commerce will initiate an investigation into whether the quantities or circumstances of imports of vanadium into the United States threaten to impair U.S. national security. This investigation is the result of a petition filed by U.S. producers AMG Vanadium LLC (Cambridge, Ohio) and…
USTR Issues Notice Seeking Public Comment on Extending China Section 301 Tariff Exclusions for List/Tranche 3 Products Set to Expire in August 2020
On May 29, 2020, the Office of the U.S. Trade Representative (USTR) released a Federal Register notice seeking public comment on whether extensions for up to 12 months should be granted for particular products that have received exclusions in the China Section 301 process from the 25 percent tariff on imports from China with an…
USTR Issues Notice Seeking Public Comment on Extending China Section 301 List/Tranche 1 Product Exclusions Set to Expire in September 2020
On May 29, 2020, the Office of the U.S. Trade Representative (USTR) released a Federal Register notice seeking public comment on whether extensions for up to 12 months should be granted for particular products receiving exclusions in the China Section 301 process from the 25 percent tariff on imports from China with an annual trade…
White House Releases Report on Strategic Approach to China
On May 26, 2020, as required under the FY2019 National Defense Authorization Act, the White House released its report, “United States Strategic Approach to the People’s Republic of China,” detailing a government-wide strategy concerning the People’s Republic of China (China or PRC). Recognizing that 40 years of direct engagement with China has not…
Changing Hong Kong’s Special Trade Status? State Department Refuses to Certify Hong Kong’s Autonomy
Hong Kong currently enjoys special trade status with the United States in comparison to China, as a result of China’s agreement in 1997 to allow Hong Kong continued autonomy in many economic and administrative ways. As recent press articles have indicated, the People’s Republic of China (PRC) has increasingly cracked down on the Hong Kong…
DOJ Charges 33 Individuals for $2.5B Scheme Violating North Korea Sanctions
The U.S. Department of Justice unsealed an indictment charging 28 North Korean and 5 Chinese individuals (“Defendants”) with facilitating more than $2.5 billion in illegal payments for Pyongyang’s nuclear weapons and missile program through North Korea’s state-owned Foreign Trade Bank (“FTB”). DOJ alleges that the scheme involved “covert branches” of FTB in China, Russia, Libya,…
State Department Ends Sanctions Waiver Program on JCPOA-Related Iran Nuclear Projects; OFAC Designates Two Iranian Officials
On May 27, 2020, Secretary of State Mike Pompeo announced that the United States was ending the sanctions waiver pertaining to the remaining nuclear projects in Iran covered by the Joint Comprehensive Plan of Action (JCPOA) – the Arak reactor modernization conversion, the provision of enriched uranium for the Tehran Research Reactor, and the export…
