Sanctions

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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,…

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…

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…

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…

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,…

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…

On May 14, 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard issued a global advisory to alert the maritime industry and those active in the energy and metals sectors to deceptive shipping practices used to evade U.S. economic sanctions.  It is intended to provide exporters, shippers and others utilizing the…

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its revocation of general license 13E and issuance of general licenses 3H (“Authorizing Transactions Related to Dealings in Certain Bonds”) and 9G (“Authorizing Transactions Related to Dealings in Certain Securities”) to remove references to Nynas AB. Nynas is no longer being blocked…

On April 18, 2020, President Donald Trump signed an Executive Order in an effort to support U.S. businesses that have faced significant financial hardship due to the COVID-19 pandemic response by allowing deferment of duty payments. The order gives the Treasury Department and U.S. Customs and Border Protection (CBP) the flexibility to allow for a…

On April 16, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a fact sheet noting that the sanctions programs it administers generally allow for legitimate humanitarian-related trade, assistance or activity under existing laws and regulations. The fact sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions and authorizations for…