The US Government has taken coordinated actions this week that target Huawei Technologies Co. Ltd (“Huawei”), effectively cutting it off from sourcing US products and technology and likely barring its products from being used in US communications infrastructure and networks. The US export/reexport restrictions targeting Huawei took effect immediately on May 16, 2019. The expected prohibition on the use of Huawei products in US communications infrastructure is likely to take several months to implement.Read more…
On May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets the Iranian iron and copper sectors.Read more…
The UK Parliament has approved the draft Protection against the Effects of the Extraterritorial Application of Third Country Legislation (Amendment) (EU Exit) Regulations 2019 which will transpose the EU blocking statute into UK domestic law in the event of a no-deal Brexit. The EU Blocking Regulation aims to offset the unlawful effects of third country extra-territorial sanctions on EU operators. The new UK Regulations are particularly relevant following the EU’s response to the re-imposed US sanctions against Iran (see our previous blog post here).
The draft regulations are made under the European Union (Withdrawal) Act 2018, which permits amendments to be made to EU legislation brought into domestic law on ‘exit day’ so that it makes sense as domestic legislation. The Explanatory Note to the Regulations states that the UK regulations make changes to the EU rules “to ensure that these rules operate as UK rules after withdrawal”. For instance, the provisions prohibiting EU persons from complying with the relevant third-country legislation will become provisions prohibiting UK persons from doing so.
The High Representative of the European Union and the Foreign Ministers of France, Germany and the United Kingdom released a joint statement today (see here for the full statement) following Iran’s announcement yesterday that it would withdraw from certain commitments as agreed as part of the 2015 nuclear agreement (see our post here on this).
The statement urged Iran to continue to implement its commitments under the nuclear agreement, stating that Iran’s compliance would be monitored and verified. At the same time, the three countries recalled their own commitments and reiterated their determination to try and facilitate legitimate trade with Iran, including through the operationalisation of INSTEX.
Furthermore, the statement called on countries not party to the nuclear agreement to refrain from taking any actions that may “impede the remaining parties’ ability to fully perform their commitments”.
We note that the statement does not make explicit reference to the re-imposition of EU sanctions.