On December 14, 2020, the US Government announced Sudan’s removal from the list of State Sponsors of Terrorism (the “SST List”). This rescission of Sudan as an SST follows an agreement in October for Sudan to be removed from the list and the lapse of a 45 day congressional notification period. The federal register notice regarding the rescission is available here. As detailed in our previous blog post here, the US Government revoked Sudan sanctions in October 2017,…
On October 27, 2020, the US Treasury Departmentās Office of Foreign Assets Control (āOFACā) published a final rule amending the Cuban Assets Control Regulations (āCACRā) restricting certain remittance-related transactions to and from Cuba (the āFinal Ruleā). OFAC also published updated and new Frequently Asked Questions (āFAQsā) related to transactions with Cuba. Significantly, the recent amendments will have the practical effect of making remittances to Cuba more difficult. The Final Rule becomes effective on November 26,…
On September 1, 2020, the US Department of State’s Bureau of International Security and Nonproliferation, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Department of Commerce’s Bureau of Industry and Security issued a joint advisory on North Korea’s ballistic missile procurement activities (“Advisory”). The Advisory, among other things, identifies key participants of North Korea’s ballistic missile procurement and their deceptive tactics and key items, including materials and equipment,…
On July 30, 2020, the US Department of State (“State Department”) expanded secondary sanctions targeting Iran’s nuclear, military, and ballistic missile programs under the Section 1245 of the Iranian Freedom and Counter-Proliferation Act of 2012 (“IFCA”) by including 22 specific metals used in connections with such programs in Iran.Ā Sanctions may be imposed on persons who knowingly transfer these 22 materials, in addition to the 4 materials already determined by the State Department in October…