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Laura Klick

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On 19 March 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned five companies based in the United Arab Emirates (“UAE”), pursuant to Executive Order 13846 (“EO 13846”), for their alleged involvement in purchasing hundreds of thousands of metric tons of petroleum products from the National Iranian Oil Company (“NIOC”) for delivery to the UAE. The following UAE-based companies were added to the US Specially Designated Nationals and Blocked Persons List (“SDN List”):…

Effective March 10, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued a final rule extending through May 15, 2020 the validity of the Temporary General License (“TGL”) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (“EAR”) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and 114 of its non-US affiliates designated on the BIS Entity List. The TGL had been set to expire on…

On February 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved.…

On 30 January 2020, the Swiss Federal Council announced the first successful pilot transaction under the proposed Swiss Humanitarian Trade Arrangement (SHTA), a payment mechanism designed to enable the delivery of humanitarian goods to Iran. The SHTA was developed by Switzerland since autumn 2018 with the cooperation of relevant US and Iranian authorities, along with selected Swiss and interested banks.  Once finally agreed and implemented, it will become the first US OFAC-consented humanitarian trade arrangement,…