Insights on Export Controls & Economic Sanctions

Economic sanctions turbulence continued virtually unabated in 2018 and into early 2019, making work for the sanctions experts both in and out of the US government.

With the escalating political turmoil in Venezuela over the past few weeks, the Trump Administration responded – at least in part – with the imposition of additional sanctions.

In a steady drumbeat of US sanctions targeting Iran during the month of November 2018, the Office of Foreign Assets Control has designated Iran-based financial facilitators of malicious cyber activity and, for the first time, associated digital currency addresses.

Action Alert: BIS Publishes List of Emerging Technologies That It Is Considering Subjecting to Unilateral US Export Controls. Your Company May Need to File Comments by December 19, 2018!

Back in May 2018, President Trump announced the United States’ intention to withdraw from the Joint Comprehensive Plan of Action (JCPOA) and re-impose secondary sanctions on Iran. 

All Bark and No Bite? State Department Explains Further the Waivers of the CBW Sanctions Against the Russian Government, Confirming that Many Exports, Even of National Security Controlled Items, Can Still Be Exported to Russia.

The US Administration announced that it would be imposing sanctions on the Russian Government under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) over the use of a “Novichok” nerve agent in an attempt to assassinate UK citizen Sergei Skripal.

The President issued an Executive Order on August 6, 2018, “Reimposing Certain Sanctions With Respect to Iran” (the New Iran EO), which re-imposes relevant provisions of five Iran sanctions EOs (EOs 13574, 13590, 13622, and 13645).

On May 8, 2018, President Trump announced that the United States is withdrawing from the Joint Comprehensive Plan of Action (JCPOA).

At the end of January 2018, the Trump Administration took two actions related to the Russia/Ukraine sanctions program under the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), the law that President Trump signed on August 2, 2017.

International Trade Practice Group Leader Kay Georgi and Counsel Regan Alberda discussed economic sanctions under President Donald Trump in an article for The Current: The Journal of the PLI Press.

Right before the holidays, President Trump and his Administration took significant steps toward using economic sanctions to tackle international human rights abuses and corruption.

On January 13, 2017, we announced that the Obama Administration had issued a general license allowing most transactions between US persons and the country of Sudan.

As Yogi Berra once said: “It’s deja vu all over again.” Certainly that’s how it felt on August 24, 2017, when President Trump signed Executive Order 13808 imposing additional sanctions on Venezuela. 

On July 27, 2017, the Senate voted 98-2 to pass a bill, HR 3364, to impose additional sanctions on Russia, Iran, and North Korea.

On July 27, 2017, the Senate voted 98-2 to pass a bill, HR 3364, to impose additional sanctions on Russia, Iran, and North Korea.

On July 11, 2017, President Trump issued an executive order extending the review period established by EO 13761 of January 13, 2017, which set forth criteria for the revocation of certain sanctions on Sudan and the Government of Sudan.

On Friday, June 16, 2017, President Donald Trump announced changes to the US-Cuba policy for individual travel to the island nation and engaging in transactions with entities associated with the Cuban military, intelligence or security services. 

Today the Department of the Treasury’s Office of Foreign Asset Controls issued a general license that effectively removes US sanctions against Sudan (North) effective January 17, 2017. 

On October 14, 2016, the Office of Antiboycott Compliance joined the 21st century and issued a Final Rule that permits electronic submission as an additional method to report requests.

Although the United States has had effective economic sanctions on North Korea for many years, the temporary softening of US sanctions in 2000 has given way to ever-increasing sanctions since 2008.

On April 15, the World Bank released updated public disclosures of its suspension and debarment practices against companies that violate its compliance directives.

Today, February 16, 2016, the US Department of Transportation and Cuban government officials signed a December 2015 agreement to restore commercial air travel. There have been no scheduled flights between the US and Cuba for over 50 years.

On January 16, 2016, the US Department of State and US Department of Treasury’s Office of Foreign Assets Control (OFAC) took two actions that impact the auto industry.