On March 22, 2018, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule (the “Final Rule”) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulations’ (“EAR”) Entity List — a step that increases the pressure on that country following the US Government’s imposition of an arms embargo last month. All 15 entities are subject to a license requirement for all exports, reexports, or in-country transfers of items subject to the EAR, and new license applications for these entities are subject to a presumption of denial.Read more…
US Treasury Department Identifies Russian Oligarchs and Senior Political Figures and New CAATSA Sanctions Targeting Russia Go into Effect
On January 29, 2018, the US Treasury Department (“Treasury”) delivered five reports to Congress, as required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). Please see our prior blog post on CAATSA here. Among these reports was a list identifying Russian senior political figures, oligarchs, and parastatal entities pursuant to CAATSA Section 241. This report was released during the same week that other CAATSA sanctions targeting Russia have gone into effect.Read more…
US President “Decertifies” the Iran nuclear deal and imposes new sanctions against the Iranian Revolutionary Guard Corps
On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”). By itself, this action does not mean that the United States has withdrawn from the JCPOA, nor does it reinstate sanctions that were lifted under the JCPOA. What it does do, however, is to hand the matter over to the US Congress for a 60-day review period in which Congress must decide whether the sanctions relief under the JCPOA will remain in effect. Congress is also reported to be considering new laws that would automatically re-impose US sanctions if Iran violates existing and new restrictions on its nuclear program and President Trump has threatened to use his authority to cancel US participation in the JCPOA if Congress fails to act. Against this uncertain US political backdrop, both Iran and US allies have reaffirmed their clear commitment to Iran’s compliance with the JCPOA. In parallel, Iran’s Islamic Revolutionary Guard Corps (“IRGC”), which was already designated on the List of Specially Designated Nationals and Blocked Persons (“SDN List”), has been targeted for further sanctions for its support of terrorism, resulting in the loss of certain exemptions under US sanctions.Read more…
US President Signs Iran, Russia, and North Korea Sanctions Bill
Today, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (“CAATSA”), a bill that he called “seriously flawed” in a statement about CAATSA issued at the same time he signed the bill.Read more…
