On November 9, 2016, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) imposing additional restrictions on North Korean banks and other financial institutions. The Final Rule follows a related June 3, 2016 Notice of Proposed Rulemaking and FinCEN’s June 2, 2016 Finding that North Korea is a jurisdiction of primary money laundering concern under Section 311 of the USA PATRIOT Act, 31 U.S.C. 5318A. These developments were discussed in our previous blog post.
On 23 May 2016, at a joint press conference with President Quang in Hanoi, President Obama announced the lifting of the US arms embargo against Vietnam, which had been in place in 1984. The US Department of State’s Directorate of Defense Trade Controls (DDTC) subsequently announced the end of its policy prohibiting the sale and transfer of lethal weapons to Vietnam.
Under the Joint Comprehensive Plan of Action (“JCPOA”), Saturday, January 16, 2016, was “Implementation Day.” On that date, the US Government relaxed certain sanctions against Iran after the International Atomic Energy Agency confirmed that Iran had fulfilled its nuclear-related commitments under the JCPOA. These measures primarily affect parties who are not “U.S. persons” (i.e., US citizens or permanent residents (wherever located or employed), entities organized under the laws of the United States (including foreign branches), and persons…
On October 18, 2015, President Barack Obama directed US Government agencies to take all appropriate measures to implement US commitments under the Joint Comprehensive Plan of Action (“JCPOA”). This date was “Adoption Day” under the JCPOA, or 90 days after the UN Security Council approved the agreement. We previously summarized the JCPOA in this blog post. This US action is taking place in parallel with similar action by the EU, as summarized in this blog post. In conjunction with…