Kathryn J. Anderson


On June 3, 2016, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking proposing the imposition of additional restrictions on North Korean banks and other financial institutions.  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. 

On Thursday, March 24, 2016, the US Commerce Department’s Bureau of Industry and Security (“BIS”) is scheduled to publish a temporary general license in the Federal Register relating to Zhongxing Telecommunications Equipment Corporation (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. (“ZTE Kangxun”). As detailed in a previous post, BIS added these two companies and two affiliated entities (Beijing 8-Star and ZTE Parsian) to the Export Administration Regulations’ (“EAR”) Entity List on March 8, 2016.

Under the Joint Comprehensive Plan of Action (“JCPOA”), Saturday, January 16, 2016, was “Implementation Day.” 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 “U.S. persons” (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”)announced an expansion of the List of Medical Supplies (“List”) eligible for export or reexport to Iran under the general license at Section 560.530(a)(3) of the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 CFR Part 560. ITSR § 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…