On June 3, 2016, the US Treasury Departmentās Financial Crimes Enforcement Network (āFinCENā) issued a notice of proposed rulemaking proposing the imposition of additional restrictions on North Korean banks and other financial institutions.Ā The notice follows the June 2, 2016 publication of a FinCEN 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.Ā
On Thursday, March 24, 2016, the US Commerce Departmentās Bureau of Industry and Security (āBISā) is scheduled to publish aĀ temporary general licenseĀ in the Federal Register relating to Zhongxing Telecommunications Equipment Corporation (āZTE Corporationā) and ZTE Kangxun Telecommunications Ltd. (āZTE Kangxunā). As detailed in a previousĀ post, BISĀ addedĀ these two companies and two affiliated entities (Beijing 8-Star and ZTE Parsian) to the Export Administration Regulationsā (āEARā)Ā Entity ListĀ on March 8, 2016.
Under theĀ Joint Comprehensive Plan of ActionĀ (āJCPOAā), Saturday, January 16, 2016, was āImplementation Day.ā 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 āU.S. personsā (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 November 2, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”)announcedĀ an expansion of theĀ List of Medical SuppliesĀ (āListā) eligible for export or reexport to Iran under the general license atĀ Section 560.530(a)(3)Ā of the Iranian Transactions and Sanctions Regulations (āITSRā), 31 CFR Part 560. ITSR Ā§ 560.530 sets forth a policy of permitting the export and reexport to Iran of certain EAR99 agricultural commodities, medicines and medical devices either by general or specific license. The…