Tariffs. Customs. Trade Remedies

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Iran

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On September 10, 2013, the Office of Foreign Assets Control (OFAC) issued two general licenses that authorize certain humanitarian-related activities by nongovernmental organizations in Iran and athletic exchanges involving Iran and the United States. General License E authorizes the exportation of services and funds transfers by nongovernmental organizations in support of certain not-for-profit humanitarian activities designed to benefit the people of Iran, including activities related to humanitarian projects to meet basic human needs; non-commercial reconstruction…

On September 5, 2013, the Office of Foreign Assets Control (OFAC) published in the Federal Register a notice updating the list of items defined as basic medical supplies under section 560.530(a)(3)(ii) of the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), and generally licensed for exportation or reexportation to Iran pursuant to section 560.530(a)(3)(i), to include additional items. The effective date was July 25, 2013.

On September 3, 2013, the Office of Foreign Assets Control (OFAC) published in the Federal Register a request for comments on the effectiveness of OFAC’s licensing procedures for the exportation of agricultural commodities, medicine, and medical devices to Sudan and Iran. Pursuant to section 906(c) of the Trade Sanctions Reform and Export Enhancement Act of 2000 (Title IX of Pub. L. No. 106–387, 22 U.S.C. 7201 et seq.) (the “Act”), OFAC is required to submit…

On August 1, 2013, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) published in the Federal Register a final rule [FAC 2005-69; FAR Case 2012-030; Item II; Docket 2012-0030, Sequence 1] adopting, with minor changes, the interim rule amending the Federal Acquisition Regulation (FAR) to require certifications that implement the expansion of sanctions relating to the energy sector of Iran and sanctions with respect to Iran’s Revolutionary…

On June 28, 2013, the Office of Foreign Assets Control (OFAC) announced that Intesa Sanpaolo S.p.A. (Intesa) had agreed to remit $2,949,030 to settle potential civil liability for apparent violations of the Cuban Assets Control Regulations (CACR), 31 C.F.R. part 515; the Sudanese Sanctions Regulations (SSR), 31 C.F.R. part 538; and the Iranian Transactions Regulations (ITR), 31 C.F.R. part 560.1. OFAC has determined that Intesa did not voluntarily self-disclose the apparent violations and that the…

On July 19, 2013 the Office of Foreign Assets Control (OFAC) announced that Stanley Drilling Equipment & Supply, Inc. (Stanley Drilling), Houston, TX, had agreed to pay $84,240 to settle potential civil liability for alleged violations of the Iranian Transactions Regulations, 31 C.F.R. part 560, which were renamed, amended, and reissued as the Iranian Transactions and Sanctions Regulations on October 22, 2012. The alleged violations by Stanley Drilling occurred between June 16, 2008, and October…

The US State Department’s Iran sanctions page posted yesterday a new “Overview of U.S. Sanctions on Iran Pertaining to Activities and Transactions by non-U.S. Individuals and Entities” at http://www.state.gov/documents/organization/212555.pdf. This document does not appear to provide guidance about many of the issues related to US secondary/extraterritorial sanctions targeting Iran. However, this overview does provide a laundry list of the various US sanctions that may affect non-US individuals and entities. The document is updated through EO…

On July 19, 2013, the Office of Foreign Assets Control (OFAC) published in the Federal Register a notice publishing General License D issued under the Iranian transactions sanctions program on May 30, 2013. General License D authorizes the exportation and reexportation to persons in Iran of certain services, software, and hardware incident to the exchange of personal communications, subject to certain limitations.

On July 16, 2013, the Department of State published in the Federal Register a notice [Public Notice 8381] of Report to Congress pursuant to section 1245(e) of the National Defense Authorization Act for Fiscal Year 2013 which requires that the Secretary of State, in consultation with the Secretary of the Treasury, determine (1) whether Iran is (A) using any of the materials described in subsection (d) of Section 1245 of the FY13 NDAA as a…

CSMS # 13-000349 of July 15, 2013 was issued by CBP to clarify the prohibition on imports from Iran. Prior to September 29, 2010, the only imports from Iran that were allowed into the United States were carpets, textile floor coverings, carpets used as wall hangings, and foodstuffs for human consumption, with limited exceptions. Effective September 29, 2010, imports of carpets, textiles, and foodstuffs from Iran were no longer authorized by the Department of the…