On September 19, 2020, the US State Department issued a press release announcing the re-imposition of sanctions against Iran pursuant to the snapback process under UN Security Council Resolution 2231, the resolution that essentially terminated all UN sanctions on Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”). At the same time, the international community has rejected this unilateral US attempt to snapback UN sanctions. To implement the snapback of UN sanctions, on September…
On July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”)…
On May 29, 2020, the president announced in a White House press conference the Administration’s determination that Hong Kong is no longer sufficiently autonomous from the People’s Republic of China (“PRC”), and that the US Government would take “strong and meaningful” steps to “begin the process” of reviewing and revoking the “full range of agreements” that currently provide Hong Kong with preferential treatment under US law. This determination follows Secretary of State Michael Pompeo’s certification…
On June 24, 2019, the President issued Executive Order 13876, “Imposing Sanctions With Respect To Iran” (“EO 13876”), which specifically imposes sanctions on the Supreme Leader of Iran (currently, Ayatollah Khamenei) and the Supreme Leader’s Office (“SLO”), authorizes the future designation of persons appointed by, or providing support to, the SLO, and designates certain additional senior Iranian Revolutionary Guard (“IRGC”) commanders. While a politically significant and symbolic move, by itself this latest action is unlikely to have much practical impact, except to increase the risk, yet again, of secondary sanctions for non-US parties (particularly financial institutions) that engage in transactions with the targeted parties.