On January 13, 2017, President Obama issued Executive Order, “Recognizing Positive Actions by the Government of Sudan and Providing for the Revocation of Certain Sudan-Related Sanctions” (“Sudan Executive Order”) to revoke in six months’ time the sanctions provisions of Executive Orders 13067 and 13412, which form the basis for US sanctions targeting Sudan, which are implemented through the Sudanese Sanctions Regulations (“SSR”). The provisions of the Sudan Executive Order that will terminate these US sanctions against Sudan will go into effect on July 12, 2017, provided the Government of Sudan continues the positive progress it has made in the past six months.
Extension of the Iran Sanctions Act
On December 15, 2016, the Iran Sanctions Extension Act (H.R. 6297) went into effect and extended the Iran Sanctions Act of 1996 (“H.R. 6297”) for 10 years through December 31, 2026. H.R. 6297 was approved by the House of Representatives in a 419-1 vote and by the Senate in a 99-0 vote. It became law without President Obama’s signature.
On November 9, 2016, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) imposing additional restrictions on North Korean banks and other financial institutions. The Final Rule follows a related June 3, 2016 Notice of Proposed Rulemaking and FinCEN’s June 2, 2016 Finding that North Korea is a jurisdiction of primary money laundering concern under Section 311 of the USA PATRIOT Act, 31 U.S.C. 5318A. These developments were discussed in our previous blog post.
On October 7, 2016, the US Treasury Department’s Office of Foreign Assets Control (OFAC) updated its list of Frequently Asked Questions (FAQs) Relating to the Lifting of Certain US Sanctions under the Joint Comprehensive Plan of Action (JCPOA). These updates provide clarification on existing OFAC guidance originally issued in January 2016 and most recently updated in June 2016. For more information on the June 2016 updated guidance, please see our blog post here.