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Tariffs. Customs. Trade Remedies

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Alexandre Lamy (US)

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United States: A new approach to OFAC’s rejected-transactions reporting

By 1 Min Read

In June 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control, or OFAC, significantly changed the scope of reporting requirements related to so-called rejected transactions, particularly in terms of expanding the reporting base beyond financial institutions and funds transfers. In February, OFAC issued FAQs to confirm that these reporting requirements apply to companies outside the financial sector.However, OFAC has not provided public guidance to nonfinancial sectors seeking to comply with U.S. sanctions…

US – FEMA Implements Export Restrictions on Certain PPE Products, with Immediate Effect

By and 5 Mins Read

On Tuesday, April 7, 2020, the Federal Emergency Management Agency (“FEMA”) filed a temporary final rule (“Rule”) in the Public Inspection issue of the Federal Register to establish export restrictions on certain types of personal protective equipment products (“PPE Products”) used in the response to the COVID-19 pandemic. The Rule implemented the order via Presidential Memorandum (“Order”) dated April 3, 2020, in which the President directed the US Department of Homeland Security, of which FEMA is a part, to…

Client Alert – Focus on Iran: U.S. Government, European Union, and Switzerland Implement Limited Sanctions Easing Under Joint Plan of Action

By , and 1 Min Read

I. U.S. SanctionsAs reported in our Client Alert dated November 27, 2013, the United States and its partners in the P5+1 (i.e., China, France, Germany, Russian, and the United Kingdom) reached an initial understanding with Iran on November 24, 2013, outlined in a Joint Plan of Action (“JPOA”), targeted at gaining commitments from Iran on enrichment reductions, non-proliferation, and inspections of its nuclear program. In return, the P5+1 nations agreed to a gradual, step-by-step suspension…

Iran sanctions summary from the US State Department

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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…

April 30 Webinar: Iran Threat Reduction and Syria Human Rights Act: Lessons Learned from the First Round of Securities Disclosures

By and 3 Mins Read

Please join us on Tuesday, April 30, 2013 at 11:00 a.m. (ET) for a complimentary webinar to discuss the initial implementation of Sections 218 and 219 of the Iran Threat Reduction and Syria Human Rights Act (the “ITRA”). Pamela K. Dayanim will discuss approaches issuers have taken in addressing the new federal securities disclosure requirements and factors companies will need to consider in making future disclosures. Alexandre Lamy will discuss international trade considerations companies need…

State and Local Divestment Measures: A Growing US Trade Compliance Concern

By and 10 Mins Read

STATE AND LOCAL DIVESTMENT MEASURES: A GROWING U.S. TRADE COMPLIANCE CONCERNAlexandre Lamy and Maria van Wagenberg, Baker & McKenzie In recent years, a growing number of U.S. state and local governments have adopted divestment measures targeting companies doing business or investing in Iran and Sudan, among other countries. These divestment measures typically prohibit governmental entities from investing in or contracting with certain listed companies. Because federal sanctions already prohibit U.S. companies from engaging in virtually all…