Author

Kevin Nordin

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On 20 March 2020, the Export Control Joint Unit (ECJU) of the Department for International Trade published a Notice to exporters 2020/08: coronavirus (COVID-19) – export licence handling. The notice states that the ECJU is taking measures to ensure minimum disruption to the export licence application process, as well as to the advice they provide. The ECJU has identified processing applications for strategic export licences as a business-critical operation for the Department for International Trade…

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 By itself, this action does not mean that the United States has withdrawn from the JCPOA, nor does it reinstate sanctions that were lifted under the JCPOA.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.