The Bureau of Industry and Security (BIS) is extending the comment period for its November 19, 2018, advanced notice of proposed rulemaking (ANPRM), “Review of Controls for Certain Emerging Technologies” until January 10, 2019. In response to requests received from members of the public, BIS believes it is appropriate to extend the comment period to provide interested parties additional time to submit their responses to the ANPRM. See our previous blog post here.
US trade sanctions and export controls targeting Iran have attracted increasing attention from Chinese companies doing business in Iran or with Iran counterparties. This client alert aims to provide a high-level overview on US trade sanctions and export controls targeting Iran, their implications (particularly in terms of their extraterritorial application), and the potential penalties that can be imposed on companies and their executives and employees in the event of violations.Read more…
Ukraine introduced martial law ending on 26 December 2018 in 10 regions of Ukraine bordering the Russian Federation, Belarus and Moldova’s Trans-Dniester area (Vinnytsia, Luhansk, Mykolaiv, Odesa, Sumy, Kharkiv, Chernihiv, Donetsk, Zaporizhia and Kherson regions), and in the internal waters of Ukraine in the Azov-Kerch water area.
On November 23, 2018 the Russian Government issued Decrees No. 1403, No. 1404, No. 1405 (“Decrees“), establishing the right of Russian banks and credit institutions that fall under foreign sanctions to not disclose certain information that is normally subject to mandatory disclosure requirements.
In particular, the Decrees prescribe such banks and credit institutions to provide information on its shareholders and UBOs only to the Central Bank of Russia and to give motivated explanations. The Central Bank of Russia is recommended to not disclose such information publicly.
According to the Russian Government, the above measures are intended to safeguard the interests of Russian banks and credit institutions that fall under sanctions imposed by foreign states.
The Decrees are expected to come into force on December 5, 2018.