On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the
Iran
Trump Administration Issues Additional Iranian Sanctions, Targeting Iranian Banks and Affecting Foreign Banking Transactions
On October 8, 2020, the Departments of State and the Treasury announced sanctions on numerous Iranian financial institutions. The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has sanctioned eighteen major Iranian banks. Secretary of the Treasury Steven Mnuchin stated that the sanctions “reflect our commitment to stop illicit access to U.S.…
U.S. Government Issues Significant New Sanctions on Iran, Unilaterally Triggering “Snapback” UN Sanctions on Iran
On September 19, 2020, the United States announced that virtually all United Nations (UN) sanctions on Iran were being re-imposed. President Donald Trump and Secretary of State Mike Pompeo have taken the position that the United States can trigger the “snapback” provisions of UN sanctions under UN Security Council resolution 2231 pursuant to the Joint…
BIS Adds 47 Entities to the Entity List Effective September 22
In a Federal Register notice, the Department of Commerce’s Bureau of Industry and Security (BIS) has announced that effective September 22, 2020, it is adding 47 entities to its Entity List after determining these companies and persons to be acting contrary to the national security or foreign policy interests of the United States. The entities…
Departments of State and the Treasury Impose Additional Sanctions on Iran
On September 3, 2020, the Department of State and the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned numerous entities and persons for their reported involvement with the petroleum or petroleum sector of Iran. According to a press statement from Secretary of State Michael Pompeo, the targeted entities and persons have “continued…
Department of Commerce Adds 60 Companies to the Entity List, Including 24 Chinese Companies, for Involvement in Militarizing the South China Sea
On August 26, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that it was adding 24 Chinese companies to the Entity List for their role in helping the Chinese military construct and militarize the internationally condemned artificial islands in the South China Sea. “The United States, China’s neighbors, and the international…
Commerce and Treasury Departments Sanction Entities Supporting Iran’s Mahan Air
The Department of Commerce’s Bureau of Industry and Security (BIS) and the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against several persons and entities determined to be supporting Iran’s Mahan Air in violation of U.S. sanctions toward Iran. According to both agencies, the involved companies have provided key parts and logistics services…
OFAC Sanctions Target Iran’s Metals Sectors
On June 25, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that its recent designations to the Specially Designated Nationals and Blocked Entities (SDN) List targeted Iran’s steel, aluminum, copper, and iron sectors. OFAC designated eight entities operating in the Iranian metals sector including companies from Iran, the United…
State Department and OFAC Issue Additional Sanctions on Iranian Shipping Entities
On June 8, 2020, the State Department announced sanctions against the Islamic Republic of Iran Shipping Lines (IRISL) and its Shanghai-based subsidiary, E-Sail Shipping Company Ltd (E-Sail) pursuant to Executive Order 13382, which targets weapons of mass destruction (WMD) proliferators and supporters. In a press statement, Secretary of State Mike Pompeo noted that,…
OFAC Issues FAQs Related to Sanctions on Iran’s Construction, Mining, Manufacturing and Textile Sectors
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…