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US – OFAC issues COVID-19-related General licenses for Syria, Venezuela, and Iran

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On June 17, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued three pandemic-related general licenses (“GLs“) authorizing certain transactions and activities through June 16, 2022, involving Syria, Venezuela, Iran, or certain blocked entities in these countries. The new GLs are Syria General License No. 21, Venezuela General License No. 39, and Iran General License N,  and they authorize certain transactions and activities related to the prevention, diagnosis, or treatment of COVID-19 (including research or…

US – Commerce publishes interim final rule on Securing the Information and Communications Technology and Services Supply Chain; Comments due March 22, 2021

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On January 19, 2021, the Commerce Department published an interim final rule to implement President Trump’s 2019 Executive Order 13873 on “Securing the Information and Communications Technology and Services Supply Chain” (“Interim Rule”). The Interim Rule was issued following the closure of the public comment period on January 10, 2021 on the proposed rules issued on November 27, 2019 (“Proposed Rules”) to implement Executive Order 13873. For more information on Executive Order 13873 and the Proposed Rules, please see our blog…

UK government publishes guidance on UK implementation of EU Blocking Regulation post-Brexit

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The UK Department for International Trade has recently published guidance on how the UK will transpose and implement the EU Blocking Regulation (Council Regulation (EC) 2271/96) post-Brexit. The EU Blocking Regulation seeks to counter the extra-territorial impact of certain US sanctions (the “proscribed US sanctions”), currently in respect of Iran and Cuba (please see our previous blog post on updates of the EU Blocking Regulation in respect of Iran here). During the transition period, the EU…

US – OFAC designates additional Iranian persons; issues General License 8A to cover humanitarian transactions involving NIOC

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On October 26, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated additional Iranian individuals, entities and vessels to the Specifically Designated Nationals and Blocked Persons List (the “SDN” List) pursuant to Executive Order 13224 (as amended) (EO 13224), a counter-terrorism authority, for their support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), an entity designated under EO 13224. Among the designated entities are the Iranian Ministry of Petroleum, the National Iranian Oil…

US Government imposes sanctions on the Iranian financial sector under Executive Order 13902 and designates 18 Iranian banks

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On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) identified the Iranian financial sector as subject to Executive Order (EO) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many humanitarian transactions and activities will…

US – OFAC amends WMD Proliferators Sanctions Regulations and Iranian Transactions and Sanctions Regulations

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On October 1, 2020, the Office of Foreign Assets Control (OFAC), Treasury, published in the Federal Register a final rule amending the Weapons of Mass Destruction Proliferators Sanctions Regulations (WMD Regulations; 31 CFR part 544) to update a note to describe how persons designated pursuant to the WMD Regulations for North Korea-related activities are identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List). Specifically, OFAC is amending the note to explain that…

US – Homeland Security ends arrival restrictions for flights carrying persons arriving from or present in certain countries

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On September 15, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document that announces the decision of the Secretary of the Department of Homeland Security (DHS) to terminate arrival restrictions applicable to certain flights. Specifically, the document terminates arrival restrictions that are applicable to flights carrying persons who had recently traveled from, or were otherwise present within, the People’s Republic of China (excluding the…

US – OFAC releases FAQs providing guidance on the Iran Sectoral Sanctions in Executive Order 13902

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On June 5, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published four Frequently Asked Questions (FAQs) regarding Iran-related sanctions under Executive Order 13902 (EO 13902). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs reconfirm that Iranian manufacturers of medicines,…

US Government issues updated guidance regarding shipping practices used to evade sanctions, with a focus on North Korea, Iran, and Syria

By 2 Mins Read

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 may wish…

US – OFAC issues guidance on the provision of humanitarian assistance to Iran in response to the Coronavirus outbreak

By 2 Mins Read

The US Treasury Department’s Office of Foreign Assets Control (OFAC) has issued an FAQ providing guidance relating to the provision of humanitarian goods and assistance to Iran in response to the Coronavirus Disease 2019 outbreak there. The guidance summarizes existing legal authorities that may authorize such humanitarian activities, which include: The making of humanitarian donations from the US or by US persons to recipients in Iran (other than to the Government of Iran, persons on OFAC’s SDN…