Author

Kerry B. Contini

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The Non-SDN Menu-Based Sanctions List On December 14, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published a new Non-SDN Menu-Based Sanctions List (“NS-MBS List”). The NS-MBS List is not the result of new sanctions but rather is designed as a reference tool to identify persons subject to certain non-blocking menu-based sanctions, including certain sanctions described in Section 235 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), as implemented by…

On October 26, 2020, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated additional Iranian individuals, entities and vessels to the Specifically Designated Nationals and Blocked Persons List (the “SDN” List) pursuant to Executive Order 13224 (as amended) (“EO 13224”), a counter-terrorism authority, for their support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”), an entity designated under EO 13224. Among the designated entities are the Iranian Ministry of Petroleum, the…

On September 21, 2020, the Federal Emergency Management Agency (“FEMA”) pushed back the submission deadline for comments related to the letter of attestation process for exports of certain personal protection equipment (“PPE”). FEMA published the request for comments in July 2020 but reportedly did not receive any. The export restrictions and letter of attestation process was created earlier this year in response to potential shortages of certain kinds of PPE as a result of the COVID-19…

In brief On 29 August 2020, the United Arab Emirates (“UAE”) Government’s Emirates New Agency (Wakalat Anba’a al Emarat, or ‘WAM’) publicly announced that H.H. Sheikh Khalifa Bin Zayed Al Nahyan, President of the UAE, issued Federal Decree Law No. 4 of 2020, abolishing Federal Decree Law No. 15 of 1972 Concerning the Arab League Boycott of Israel (the “UAE Israeli Boycott Law”) (the “UAE Israeli Boycott Repeal Law”).  The UAE Israeli Boycott Repeal Law…