On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”). The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies…
In a judgement of 7 April 2020 (ECLI:NL:HR:2020:623), the Dutch Supreme Court confirmed that the EU Blocking Regulation (“EUBR”) does not prevent extradition of an Iranian national to the United States for their alleged involvement in US export controls and sanctions violations. With this judgement, the Supreme Court upheld the judgement of the District Court of Rotterdam of 5 July 2019 (ECLI:NL:RBROT:2019:5338). This case was triggered by an extradition request for an Iranian national…
On 31 March 2020, the UK Foreign and Commonwealth Office (“FCO”) announced that the Instrument in Support of Trade Exchanges (INSTEX) had successfully concluded its first transaction. This transaction involved the successful export of medical goods from Europe to Iran, and paves the way for future transactions. In its announcement, the FCO stated: “Now the first transaction is complete, INSTEX and its Iranian counterpart STFI [(Special Trade and Finance Instrument)] will work on more transactions…
Representatives of China, France, Germany, Russia, the United Kingdom and Iran met on 26 February 2020 at a meeting of the Joint Commission of the Joint Comprehensive Plan of Action (JCPOA). All participants reaffirmed their commitment to the JCPOA and their strong support and collective responsibility for the continuation of key nuclear non-proliferation projects. The meeting follows the announcement on 14 January 2020 that the JCPOA Dispute Resolution Mechanism had been initiated by the E3 Foreign Ministers (see our earlier blog post here); the time limit for Joint Commission consideration of Iran’s actions was extended without a specific deadline at the end of January (extending the 15 day period that was triggered on 14 January).