Jennifer Trock (USA), Alison J. Stafford Powell (USA), Inessa Owens, Alexander Matthews (USA), Ryan Poitras, Author at Global Sanctions and Export Controls Blog

Commerce Department Amends the Export Administration Regulations to Implement Revised Unmanned Aerial System Licensing Review Policy

January 26, 2021 By Jennifer Trock (USA), Alison J. Stafford Powell (USA), Inessa Owens, Alexander Matthews (USA) and Ryan Poitras 3 Mins Read

On January 12, 2021, the US Department of Commerce issued a final rule (the “Final Rule”) amending the Export Administration Regulations (“EAR”) to implement recent licensing review policy changes for exports of US-origin unmanned aerial systems (“UAS”), also known as “drones.” Our prior blog posts on UAS export policy developments are available here and here. The Final Rule implements the more flexible export license review policy applicable to a specific subset of UAS with maximum…

US Government Imposes Sanctions on the Iranian Financial Sector under Executive Order 13902 and Designates 18 Iranian Banks

October 15, 2020 By Meghan Hamilton, Ryan Poitras and Janet K. Kim (USA) 4 Mins Read

On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many…

OFAC Releases FAQs Providing Guidance on the Iran Sectoral Sanctions in Executive Order 13902

July 17, 2020 By Sylwia Lis (USA), Lise S. Test (USA) and Ryan Poitras 6 Mins Read

On June 5, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) published four Frequently Asked Questions (the “FAQs”) regarding Iran-related sanctions under Executive Order 13902 (“EO 13902”). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs…

The Trump Administration Issues Executive Order 13920 to Protect the US Bulk-Power System from Foreign Adversaries

May 6, 2020 By Meghan Hamilton, Ryan Poitras and Terence Gilroy (USA) 3 Mins Read

On May 1, 2020, the Trump Administration issued Executive Order 13920 on “Securing the United States Bulk-Power System” (“Bulk-Power System EO”), which aims to prevent “foreign adversaries” from exploiting vulnerabilities in the US bulk-power system in furtherance of US national security. As explained in further detail in the press release concurrently published by the Department of Energy, the Bulk-Power System EO is meant to prohibit certain transactions involving bulk-power system equipment where the Secretary of…