On Thursday, December 31, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued the Cyber-Related Sanctions Regulations, 31 C.F.R. Part 578 (“Regulations”), which implement Executive Order 13694 of April 1, 2015 (“Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities” or the “Cyber EO”). Our prior blog post on the Cyber EO is available here. The Regulations implement the restrictions on transactions involving parties designated as Specially Designated Nationals (“SDNs”) under the Cyber…
On October 29, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Belarus-related General License No. 2, authorizing transactions otherwise prohibited by, and involving Belarusian entities blocked pursuant to, Executive Order 13405. The general license is effective only from October 30, 2015 through April 30, 2016, unless extended or revoked. General License No. 2 applies to all Belarusian entities currently identified as specially designated nationals (“SDNs”) pursuant to Executive Order 13405, and any entities…
On 2 September 2015, the US Commerce Department’s Bureau of Industry and Security (“BIS”) amended the Export Administration Regulations (“EAR”) to add 29 parties to the Entity List for violating international law and fueling the conflict in eastern Ukraine. The additions were made to ensure the efficacy of existing US sanctions on Russia. The 29 parties are located in the Crimea region of Ukraine, Cyprus, Finland, Romania, Romania, Russia, Switzerland, Ukraine, and the United Kingdom…
On 14 July 2015, Iran and the EU/E3+3 (China, France, Germany, the Russian Federation, the United Kingdom, the United States, and the European Union) announced that they had agreed on a Joint Comprehensive Plan of Action (“JCPOA” or “Agreement”) regarding the lifting of sanctions currently imposed against Iran. If fully implemented, the JCPOA will ultimately see the comprehensive lifting of all UN Security Council (“UNSC”) sanctions targeting Iran, as well as multilateral and national sanctions…