On March 22, 2018, 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
On March 14, 2018, the Federal Register published Presidential Notice of March 12, 2018 – Continuation of the National Emergency With Respect to Iran, which extends for an additional year the national emergency originally declared on March 15, 1995 by Executive Order (EO) 12957 to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by the actions and policies of the Government of Iran.
On November 8, 2017, the Federal Register published Presidential Notice of November 6, 2017 – Continuation of the National Emergency With Respect to Iran, which continues for an additional year the national emergency first declared in Executive Order (E.O.) 12170 (November 14, 1979)
On October 31, 2017, the Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule amending the Global Terrorism Sanctions Regulations pursuant to section 105 of the Countering America’s Adversaries Through Sanctions Act of 2017 Pub. L. 115-44, Aug. 2, 2017, 131 Stat. 886 (22 U.S.C. 9401 et seq.) (CAATSA).
Following President Trump’s October 13 announcement on the Iran nuclear deal, we are pleased to present a webinar on November 6 at 11 am Eastern Time entitled “Iran Sanctions: What’s Next?” that will explore the implications of the announcement for the future of Iran sanctions. Click here to view the invitation and register.
On October 13, 2017, President Trump announced that he was “decertifying” Iran’s compliance with the Joint Comprehensive Plan of Action (“JCPOA”). By itself, this action does not mean that the United States has withdrawn from the JCPOA, nor does it reinstate sanctions that were lifted under the JCPOA. What it does do, however, is to hand the matter over to the US Congress for a 60-day review period in which Congress must decide whether the sanctions relief under the JCPOA will remain in effect.
On August 2, 2017, the President signed into law the “Countering America’s Adversaries Through Sanctions Act” (“CAATSA”), a bill that he called “seriously flawed” in a statement about CAATSA issued at the same time he signed the bill.
On July 27, 2017, the US Senate approved in a 98-2 vote H.R. 3364, the “Countering America’s Adversaries Through Sanctions Act” (“H.R. 3364”). We previously summarized H.R. 3364 in our blog posts here and here.
Last month, the US Senate passed significant Russia sanctions legislation as an amendment to an Iran sanctions bill targeting Iran’s ballistic missile program. The Russia sanctions provisions sought to limit the President’s ability to relax existing US sanctions targeting Russia while imposing additional restrictions impacting various sectors of the Russian economy. The key provisions of the Senate bill are summarized in our earlier blog post.
On May 26, 2017, the Department of State published in the Federal Register a determination and certification [Public Notice: 10006] to Congress that the following countries are not cooperating fully with United States antiterrorism efforts: Eritrea, Iran, Democratic People’s Republic of Korea (DPRK, or North Korea), Syria and Venezuela The determination and certification were made under section 40A of the Arms Export Control Act.