Hannah N. Zarkar


On August 24, 2018, the US State Department gave notice of new sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) after determining that the Russian Government has used chemical weapons in violation of international law or chemical or biological weapons against its own nationals.  The imposition of CBW Act sanctions follows reports of the use of a “Novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal and his daughter Yulia Skripal.  There is no indication in the notice regarding the potential for significant additional sanctions (e.g., an export ban, an import ban, an air transportation ban) to be imposed in three months time, as previously described here.  

On May 22, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License 15 (“GL 15”) and General License 12C (“GL 12C”), replacing and superseding General License 12B (“GL 12B”).  Please see our prior blog posts concerning (i) the designation of certain Russian parties here and (ii) the issuance of GL 12B here.

Executive Summary Effective May 8, 2018, the US Government withdrew from the Joint Comprehensive Plan of Action (“JCPOA”). The US Government will re-instate the sanctions that were lifted or waived following the implementation of the JCPOA. This action has a greater impact on non-US persons because most of the lifted or waived sanctions were secondary sanctions targeting activities of non-US companies occurring outside of US jurisdiction. The sanctions will be re-instated on August 7,…

On May 8, 2018, President Trump announced that the United States will be withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”), culminating months of uncertainty around the fate of the Iran nuclear deal. The announcement came ahead of a May 12 deadline for the renewal of a key sanctions waiver. As described here, the last sanctions waiver occurred on January 12, 2018 amidst statements by President Trump that the waiver would be the last unless what President Trump considered “flaws” in the deal were fixed. In his May 8 speech, President Trump announced that the United States would re-impose nuclear sanctions against Iran.