On October 7, 2016, the Office of Foreign Assets Control (OFAC) updated the Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action, amending two FAQs related to Financial and Banking Measures (C.7 and C.15), amending one FAQ related to Foreign Entities Owned or Controlled by U.S. Persons (K.19), and adding three FAQs related to due diligence (M.10, M.11., and M.12). OFAC updated these FAQs to provide further…
On 3 August 2016, a notice updating the HM Treasury’s Consolidated List regarding three entities listed under Council Regulation (EU) 267/2012, which imposes financial sanctions against Iran, was published..
This notice removes the asset freeze against the below three Iranian entities, following Judgments of the General Court of the European Union (please see here and here for the relevant judgments):
On July 29, 2016, the Office of Foreign Assets Control (OFAC) issued General License J, “Authorizing the Reexportation of Certain Civil Aircraft to Iran on Temporary Sojourn and Related Transactions.” The general license authorizes the reexportation by a non-U.S. person of Eligible Aircraft (as defined in the general license) to Iran on temporary sojourn, provided all of the criteria set forth below are satisfied.
(1) the right to hire and fire the cockpit crew remains with the non-U.S. person reexporter;
(2) the right to dispatch the Eligible Aircraft remains with the non-U.S. person reexporter;
(3) the right to determine the Eligible Aircraft’s routes remains with the non-U.S. person reexporter;
(4) the right to perform or obtain the principal maintenance on the Eligible Aircraft remains with the non-U.S. person reexporter, and principal maintenance will take place outside of Iran under the control of a party who is not an Iranian national ordinarily resident in Iran;
On June 21, 2016, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule amending the Export Administration Regulations (EAR) by adding thirty-six (36) persons to the Unverified List (the ‘‘Unverified List’’ or UVL), and adding an additional address for one (1) person currently listed on the UVL. The 36 persons are being added to the UVL on the basis that BIS could not verify their bona fides because an…
On April 20, 2016, the Department of State published in the Federal Register a document [Public Notice: 9527] setting forth the Secretary of State’s designation of “countries of particular concern” for religious freedom violations pursuant to Section 408(a) of the International Religious Freedom Act of 1998 (Pub. L. 105-292), as amended (the Act). The Secretary has designated each of the following as a “country of particular concern” under the Act, for having engaged in or…
On April 20, 2016, the Department of State published in the Federal Register a document [Public Notice: 9527] setting forth the Secretary of State’s designation of “countries of particular concern” for religious freedom violations pursuant to Section 408(a) of the International Religious Freedom Act of 1998 (Pub. L. 105-292), as amended (the Act). The Secretary has designated each of the following as a “country of particular concern” under the Act, for having engaged in…
On March 14, 2016, the Office of Foreign Assets Control (OFAC) published in the Federal Register a notice publishing the names of 59 individuals, 385 entities, 76 aircraft, and 227 vessels that were removed from the List of Specially Designated Nationals and Blocked Persons (SDN List), the Foreign Sanctions Evaders (FSE) List, and/or the Non-SDN Iran Sanctions Act (NS–ISA) List on January 16, 2016— Implementation Day of the Joint Comprehensive Plan of Action of…
On March 10, 2016, the Federal Register published Presidential Notice of March 9, 2016—Continuation of the National Emergency With Respect to Iran, which continues for an additional year, the national emergency first declared on March 15, 1995 in 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. Subsequently,…
On 19 February 2016, Foreign Minister M. McCully announced that New Zealand has completed the domestic processes required to lift the United Nations sanctions against Iran. The United Nations (Iran—Joint Comprehensive Plan of Action) Regulations 2016 (SR 2016/9), which come into force on 19 February 2016, replace the current United Nations Sanctions (Iran) Regulations 2010 by imposing a new suite of restrictions in relation to Iran to give effect to UN Security Council Resolution 2231,…
On February 5, 2016, Global Affairs Canada announced changes to Canada’s economic sanctions against Iran under the Special Economic Measures Act and the United Nations Act and signalled Canada’s willingness to resume dialogue with Iran. The announcement said Canada welcomed the January 16, 2016, confirmation by the International Atomic Energy Agency that Iran had fulfilled all necessary commitments under the Joint Comprehensive Plan of Action (JCPOA). Canada has therefore amended its broad-reaching autonomous sanctions against…