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 June 30, 2015, the P5+1, the EU, and Iran decided to extend the Joint Plan of Action (“JPOA”) for seven days in order to continue ongoing negotiations. Accordingly, both the US Government and the EU have announced that the temporary sanctions relief provided for in the JPOA would be extended through July 7, 2015. As part of this extension, all specific licenses with an expiration date of June 30, 2015 that were issued…
On May 18, 2015, the US Commerce Department’s Bureau of Industry and Security (“BIS”) issued additional guidance on due diligence measures that US exporters should take to prevent unauthorized exports to Russia of items (i.e., goods, software, technology) subject to the Export Administration Regulations, 15 C.F.R. Part 730 et seq. (“EAR”). This Russia-focused guidance supplements existing “Know Your Customer” guidance found in the EAR. In connection with the crisis in the Ukraine that began in…
As anticipated in our earlier blog entry, on September 17, 2014, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) implemented new restrictions on the export, reexport and transfer (including in-country transfer) of items subject to the Export Administration Regulations (“EAR”) to certain major Russian energy and defense sector companies by adding those companies to the Entity List. BIS also has amended the EAR to impose licensing requirements on the export, reexport, and…