Kathryn J. Anderson, Bart M. McMillan (USA), Author at Global Sanctions and Export Controls Blog

US Bureau of Industry and Security Updates Export Compliance Guidelines

February 15, 2017 By Kathryn J. Anderson and Bart M. McMillan (USA) 2 Mins Read

On February 8, 2017, the US Bureau of Industry and Security (“BIS”) announced that it has updated the content of its Export Compliance Guidelines (“Guidelines”) and Audit Module (“Module”) and combined both documents into one “easy-to-use” booklet. We understand that BIS’s primary purpose in updating the Guidelines and Module was to shorten and simplify them because, in BIS’s view, the prior versions of the documents were too long and contained too much unnecessary technical language.

OFAC Expands Certain Ag/Med Authorizations and Clarifies Definitions Related to Iranian-Origin Goods

December 29, 2016 By Kerry B. Contini (USA), Lise S. Test (USA), Sylwia Lis (USA) and Kathryn J. Anderson 7 Mins Read

On December 23, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a final rule amending the licensing provisions of section 560.530 of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (“ITSR”) and making certain other amendments to the ITSR (the “Final Rule”). Section 560.530 sets forth the favorable Ag/Med licensing regime for the export/reexport of agricultural commodities, medicine, and medical devices to Iran (i.e., “Ag/Med” licenses).

US Imposes Additional North Korea Banking Restrictions

November 14, 2016 By Kathryn J. Anderson, Bart M. McMillan (USA) and Joseph Schoorl 3 Mins Read

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.

US Government Adds North Korea Leader and Other North Korean Parties to SDN List

July 8, 2016 By Lise S. Test (USA), Edward E. Dyson and Kathryn J. Anderson 3 Mins Read

On July 6, 2016, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had added 16 new North Korean parties, including 11 individuals and 5 entities, to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The Treasury Department has issued a press release related to the designations. The new SDNs include North Korea leader Kim Jong Un, other top officials of the North Korean regime, and certain North Korean government entities. The parties were designated as Specially Designated Nationals (“SDNs”) pursuant to Executive Orders 13722 and 13687 for their ties to human rights abuses in North Korea.