Steven F. Hill


On 3 June 2016, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a Final Rule (the “BIS Final Rule”) revising a number of definitions in the Export Administration Regulations (“EAR”). BIS also posted new Frequently Asked Questions related to this rule. Concurrently, the U.S. Department of State published an Interim Final Rule (the “State Interim Rule” and, collectively with the BIS Final Rule, the “June 2016 Rules”) revising several definitions in the International Traffic in Arms Regulations (“ITAR”). The June 2016 Rules will go into effect on 1 September 2016. The State Department will accept comments on the State Interim Rule until 5 July 2016.


Following the Democratic People’s Republic of Korea’s (“DPRK” or “North Korea“) latest nuclear test and rocket launch on 6 January 2016 and 7 February 2016 respectively, the UN Security Council (“UNSC“) unanimously adopted Resolution 2270 (2016) (the “UN Resolution“) on 2 March 2016.

The UN Resolution contains far-reaching sanctions aimed at cutting off funds for DPRK’s nuclear and other banned weapons programmes, whilst avoiding “adverse humanitarian consequences” for civilians. The UN Resolution adds sectoral sanctions, broadens the scope of the existing financial sanctions and arms embargo, imposes new measures targeting proliferation networks, and expands the list of designated individuals and entities.

On November 2, 2015, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”)announced an expansion of the List of Medical Supplies (“List”) eligible for export or reexport to Iran under the general license at Section 560.530(a)(3) of the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 CFR Part 560. ITSR § 560.530 sets forth a policy of permitting the export and reexport to Iran of certain EAR99 agricultural commodities, medicines and medical devices either by general or specific license. The…

On July 30, 2015, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated certain individuals and entities on the Specially Designated Nationals and Blocked Persons List (“SDN List”) and identified certain entities on the Sectoral Sanctions Identifications List (“SSI List”) pursuant to various Russia sanctions measures that have been imposed since last year.  A complete list of parties that are newly designated on the SDN List and the SSI List is available here. …