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US Imposed Sanctions

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As part of its continuing efforts to isolate North Korea from the world economy, on February 23, 2018, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced new sanctions measures targeting North Korea’s shipping industry and issued an advisory document entitled “North Korea Sanctions Advisory,” which highlights sanctions risks in the global shipping industry.

On January 29, 2018, the US Treasury Department (“Treasury”) delivered five reports to Congress, as required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”).  Please see our prior blog post on CAATSA here.  Among these reports was a list identifying Russian senior political figures, oligarchs, and parastatal entities pursuant to CAATSA Section 241.  This report was released during the same week that other CAATSA sanctions targeting Russia have gone into effect.

On January 12, 2018, the Trump Administration released a statement that the US Government would renew waivers of certain sanctions provisions in compliance with the US Government’s commitments under the Joint Comprehensive Plan of Action (“JCPOA”). This same statement indicated, however, that future waivers would not be issued unless both the US Congress and US allies in Europe take action. This development further escalates the uncertainty about the future of the JCPOA that followed the Trump Administration’s October 2017 decision not to recertify Iran’s compliance with the requirements of the nuclear deal as described here.

On November 27, 2017, the US State Department published a notice in the Federal Register that North Korea was designated as a State Sponsor of Terrorism (“SST”) on November 17, 2017. North Korea was originally designated as an SST in 1988 in connection with the bombing of a Korean Air flight but was delisted in 2008 by President George W. Bush as part of negotiations over its nuclear program.