Tariffs. Customs. Trade Remedies

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Iran

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On May 18, 2017, the Iranian Foreign Ministry announced that in response to the recent addition of names to the U.S. Iranian missile sanctions, it has added nine additional US individuals and companies to the list of banned countries published on February 3, 2017. See the announcement for the reasons given by Iran. The nine parties are:

On 17 May 2017, the US Department of State announced that the US Government would renew waivers of certain sanctions necessary to continue to implement US commitments under the Joint Comprehensive Plan of Action (“JCPOA”). On the same day, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) designated additional parties for their involvement in Iran’s military and ballistic missile program.

On 22 February 2017, S.I. 2017/83 – The Export Control (North Korea Sanctions and Iran, Ivory Coast and Syria Amendment) Order 2017 came into effect.   This Order provides for the enforcement of trade restrictions against North Korea specified in Regulation (EC) No 329/2007 concerning restrictive measures against the Democratic People’s Republic of Korea (the “North Korea Regulation”)

On January 13, 2017, the President signed the Notice of January 13, 2017 – Continuation of the National Emergency With Respect to Iran which continues the national emergency first declared in Executive Order (E.O.) 12957 of March 15, 1995 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 May 6, 1995, the President issued E.O. 12959, imposing more comprehensive sanctions on Iran to further respond to this threat. On August 19, 1997, the President issued E.O. 13059, consolidating and clarifying the previous orders. The President took additional steps pursuant to this national emergency in E.O. 13553 of September 28, 2010, E.O. 13574 of May 23, 2011, E.O. 13590 of November 20, 2011, E.O. 13599 of February 5, 2012, E.O. 13606 of April 22, 2012, E.O. 13608 of May 1, 2012, E.O. 13622 of July 30, 2012, E.O. 13628 of October 9, 2012, and E.O. 13645 of June 3, 2013.

On December 23, 2016, the Office of Foreign Assets Control (OFAC) published in the Federal Register a final rule amending the Iranian Transactions and Sanctions Regulations (ITSR) to reflect OFAC’s licensing policies and address inquiries from the regulated public. This final rule makes changes relating to authorized sales of agricultural commodities, medicine, and medical devices to Iran pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA), as amended, and clarifies the definition of the terms goods of Iranian origin and Iranian-origin goods.

On December 15, 2016, the Iran Sanctions Extensions Act became law (P. Law 114-277) without the President’s signature.  The Act extends the authority to impose sanctions under the Iran Sanctions Act of 1996 from December 31, 2016 until December 31, 2026. The Iran Sanctions Act (“ISA”) is one of the primary U.S. statutes that provides legal authority for U.S. secondary sanctions (i.e., sanctions primarily targeting non-U.S. companies engaging in certain Iran-related activities) targeting Iran. Most…

On November 7, 2016, the Federal Register published Presidential Notice of November  3, 2016 – Continuation of the National Emergency With Respect to Iran, which extends the national emergency first declared in Executive Order (EO) 12170 of November 14, 1979 to deal with the unusual and extraordinary threat to the national security, foreign policy, and economy of the United States constituted by the situation in Iran. The emergency is being continued because our relations with…

On October 28, 2016, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued interpretive guidance on the publishing of general licenses and certain exemptions found in the Iranian Transactions and Sanctions Regulations (ITSR), 31 C.F.R. §§ 560.210, 560.538, the Cuban Assets Control Regulations (CACR), 31 C.F.R. §§ 515.206, 515.577, the Sudanese Sanctions Regulations (SSR), 31 C.F.R. §§ 538.212, 538.529, the Syrian Sanctions Regulations (SySR), 31 C.F.R. §§ 542.211, 542.532, and the Burmese Sanctions…

On October 7, 2016, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) updated its list of Frequently Asked Questions (FAQs) Relating to the Lifting of Certain U.S. 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.