On March 17, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document notifying the public of certain arrival restrictions. The document announces the decision of the Secretary of Homeland Security (DHS) to direct all flights to the United States carrying persons who have recently traveled from, or were otherwise present within, the countries of the Schengen Area to arrive at one of the United…
On January 27, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued a new Counter Terrorism and Iran-related General License No. 8 (“GL 8”) together with new frequently asked questions (“FAQs”) about the general license and the Swiss Humanitarian Trade Arrangement (“SHTA”). New GL 8 authorizes US Persons and non-US entities owned or controlled by US Persons to engage in Iran-related humanitarian transactions even if the CBI is directly or indirectly involved. Although the US Government…
On March 4, 2020, US Customs and Border Protection (CBP) and the Transportation Security Administration (TSA) published in the Federal Register a document notifying the public of certain arrival restrictions. The document adds to the existing restrictions by directing all flights to the United States carrying persons who have recently traveled from, or were otherwise present within, the Islamic Republic of Iran to arrive at one of the United States airports where the USG is…
On February 14, 2020, the Department of State published in the Federal Register a notice [Public Notice: 11034] that measures imposed pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the Act) described in this notice against 13 persons went into effect February 3, 2020. A determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of…
On 30 January 2020, the Swiss Federal Council announced the first successful pilot transaction under the proposed Swiss Humanitarian Trade Arrangement (SHTA), a payment mechanism designed to enable the delivery of humanitarian goods to Iran. The SHTA was developed by Switzerland since autumn 2018 with the cooperation of relevant US and Iranian authorities, along with selected Swiss and interested banks. Once finally agreed and implemented, it will become the first US OFAC-consented humanitarian trade arrangement, and will…
The Foreign Ministers of France, Germany and the United Kingdom (the “E3 Foreign Ministers“) have today released a statement that they are triggering the dispute resolution mechanism in relation to the Joint Comprehensive Plan of Action (“JCPOA“), following Iran’s decision to no longer abide by the uranium enrichment limits of the JCPOA (see our earlier blog post on this here). In their statement, the E3 Foreign Ministers highlighted that they have triggered the dispute resolution mechanism in…
The 8 senior Iranian government officials were targeted for their involvement and complicity in Iran’s ballistic missile strikes on US bases in Iraq on January 7, 2019 and include the Secretary of Iran’s Supreme National Security Council, the Deputy Chief of Staff of the Iranian armed forces, and the head of the Basij militia of the Islamic Revolutionary Guards Corps. In addition, in an effort to constrain Iranian sources of revenue used to fund and…
As reported in our blog post of Tuesday 7 January (see here), the EU Foreign Affairs Council met on Friday 10 January 2020 to discuss recent developments involving Iran and the situation in Iraq. The EU Foreign Ministers assessed the consequences of recent events and emphasised their support for the Joint Comprehensive Plan of Action (“JCPOA“), stating that it was “a key element of the global nuclear non-proliferation architecture.” However, Ministers called for Iran to…
On December 11, 2019, the US State Department announced the designations of the Islamic Republic of Iran Shipping Lines (“IRISL”), its China-based subsidiary, E-Sail Shipping Company Ltd (“E-Sail”), and Mahan Air, a privately-owned airline based in Tehran, under Executive Order 13382 (“E.O. 13382”), for their involvement in the transporting of weapons of mass destruction (“WMD”). All three entities had previously been designated to the Specially Designated Nationals and Blocked Persons List (“SDN List”) administered by…
On November 13, 2019, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 191105-0076] that amends the Export Administration Regulations (EAR) by adding twenty-two entities, under a total of thirty-two entries, to the Entity List. These twenty-two entities have been determined by the US Government to be acting contrary to the national security or foreign policy interests of the United States. These entities will be listed on…