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Alexandre (Alex) Lamy

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The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently designated as Specially Designated Nationals (“SDNs”) a number of entities linked to the Iranian steel, aluminum, and iron sectors that are likely to be of particular interest for companies doing trade in or with the Middle East or financial institutions financing trade and business in the region. This article highlights OFAC’s recent action and outlines some practical considerations. On 25 June 2020,…

On June 17, 2020, the President signed the Uyghur Human Rights Policy Act of 2020 into law. The law authorizes the President to impose sanctions on persons, including Chinese government officials, determined to be responsible for certain human rights violations and abuses committed against Muslim minority groups in China or elsewhere. The law requires the administration to sanction those individuals by blocking their assets and declaring them ineligible for visas or admission to the United States. The President may…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020 (when published in the Federal Register), to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive…

On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”). The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies may wish…

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…

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…

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…

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…

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…