Hannah N. Zarkar


On September 21, 2017, President Trump issued an Executive Order (“Order”) imposing additional sanctions on North Korea.  The Order is aimed at curbing North Korea’s ability to fund its nuclear and ballistic missile programs by giving the Secretary of the Treasury additional tools to target non-US persons engaging in trade with North Korea and non-US financial institutions supporting such trade.

On 17 May 2017, the US Department of State announced that the US Government would renew waivers of certain sanctions necessary to continue to implement US commitments under the Joint Comprehensive Plan of Action (“JCPOA”). On the same day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated additional parties for their involvement in Iran’s military and ballistic missile program.

On 3 June 2016, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a Final Rule (the “BIS Final Rule”) revising a number of definitions in the Export Administration Regulations (“EAR”). BIS also posted new Frequently Asked Questions related to this rule. Concurrently, the U.S. Department of State published an Interim Final Rule (the “State Interim Rule” and, collectively with the BIS Final Rule, the “June 2016 Rules”) revising several definitions in the International Traffic in Arms Regulations (“ITAR”). The June 2016 Rules will go into effect on 1 September 2016. The State Department will accept comments on the State Interim Rule until 5 July 2016.

On 17 May 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Burmese Sanctions Regulations (“BSR”), 31 C.F.R. Part 537, by issuing new and amending existing general licenses intended to, support trade with Burma, facilitate the movement of goods within Burma, allow most transactions involving designated Burmese financial institutions, and allow certain transactions related to “U.S. Persons” (defined below) residing in Burma. These BSR amendments take effect today (18 May 2016) and are summarized in more detail by OFAC here.