Kathryn J. Anderson


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.

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). 

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 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.