Other Sanctions Regimes


On 17 May 2019, the Council adopted Council Regulation (EU) 2019/796 (the “Regulation”), which establishes a framework for the EU to impose sanctions in relation to cyber-attacks which constitute an external threat to the EU or its Member States. Cyber-attacks against third states or international organisations also fall within the ambit of the framework where necessary to achieve the objectives of the EU’s Common Foreign and Security Policy. The UK and the Netherlands played a…

The US Departments of State, Treasury, and Homeland Security warned companies in a new advisory that deceptive practices by North Korea to evade US, UN, and other sanctions could put them at risk of prohibited or sanctionable dealings with the North Korean regime.  The advisory published on July 24, 2018 follows February 2018 guidance from the US Treasury Department’s Office of Foreign Assets Control regarding certain deceptive shipping practices of North Korea to avoid US sanctions (see our prior blog post here).  The new advisory encourages companies to undertake enhanced due diligence within their supply chains to avoid prohibited or sanctionable: (i) sourcing of goods, services, or technology from North Korea and (ii) use of the labor of North Korean citizens or nationals, which is presumed to be forced labor, regardless of where such labor occurs.

Following on from a meeting of the EU Foreign Affairs Council (“FAC”) yesterday, at which the FAC unanimously agreed to impose restrictive measures on Venezuela, the EU has today published Council Decision 2017/2074 and Council Regulation (EU) 2017/2063 (together, the “Legislation”). The Legislation prescribes targeted sanctions against Venezuela, including an arms embargo, with immediate effect. The Legislation has been formulated in response to the continuing crisis in Venezuela and the perceived deterioration of democracy, the…

On October 1, 2017, an order from the Japanese Cabinet went into effect to implement amendments to Japan’s Foreign Exchange and Foreign Trade Act (“Act”), which implements Japanese import and export controls.  The Cabinet order was decided on July 11, 2017 and it also made relevant adjustments in the relevant regulations.  The cabinet order, the ministerial ordinance and the ministry’s notice, which are necessary to implement the amended Act, were promulgated on July 14, 2017. These regulations provide definition of terms in the amended Act as well as clerical and procedural measures for the implementation of the amended Act.