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Trade Sanctions

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On July 28, 2020, Draft Bill No. 996800 was introduced in the State Duma of Russia proposing additional Russian countersanctions (“Draft“). The Draft proposes to introduce amendments to the Federal law No. 281-FZ dated December 30, 2006 “On special economic measures and coercive actions” that sets forth the legal framework for the Russian countersanctions regime. The Draft proposes the following principal provisions: Application of the restrictive measures to the entities controlled by the sanctioned persons. These controlled…

On 28 July 2020, the EU agreed to impose EU-wide measures to restrict the export of certain items to Hong Kong. The EU Council’s press release can be found here. These restricted goods include equipment or technology that could be used for internal repression, interception of internal communications or cyber surveillance. Like recent US and UK measures, the new EU export controls have been proposed in response to the recent HK National Security Law. Germany has…

On July 15, 2020, the US Department of State (State Department) updated its guidance (“Updated Guidance“) regarding the implementation of Section 232 of Title II of the Countering America’s Adversaries Through Sanctions Act (“CAATSA” see our previous blog post on CAATSA here and our previous blog post on the 2017 State Department guidance on CAATSA Section 232 here). The Updated Guidance expands the scope of CAATSA Section 232 to target certain investments or other activities related to the Nord Stream…

On July 14, 2020, President Trump issued Executive Order 13936 on Hong Kong Normalization (the “Hong Kong Normalization EO”), which directs the suspension or elimination of special and preferential treatment for Hong Kong under a wide range of US laws, setting the stage for Hong Kong to be treated the same as mainland China. It also authorizes sanctions against persons involved in developing, adopting, or implementing China’s Law on Safeguarding National Security in the Hong…

UK extends China arms embargo to Hong Kong In Notice to Exporters 2020/12 (22 July 2020), the Export Control Joint Unit said: On 20 July 2020 the Foreign Secretary informed Parliament in an oral statement that the UK has taken measures, given the new National Security Law which China has imposed on the people of Hong Kong So we will extend to Hong Kong the arms embargo that we have applied to mainland China since 1989 and…

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 July 1, 2020, the US Department of State, jointly with the US Department of Treasury, the US Department of Commerce, and the US Department of Homeland Security, issued an advisory (the “Advisory”) to caution US businesses about the risks of supply chain links to entities that allegedly engage in human rights abuses including the forced labor of Uyghurs, ethnic Kyrgyz, ethnic Kazakhs and other Muslim minority groups, in the Xinjiang Uyghur Autonomous Region (“Xinjiang”) in China…

On 14 July 2020, the UK Government announced that Huawei would be banned from supplying new equipment for UK 5G networks from 31 December 2020, and that all existing Huawei equipment will be removed from the UK’s 5G networks by the end of 2027. The decision was taken in a meeting of the UK National Security Council (NSC) chaired by Prime Minister Boris Johnson. It follows new advice provided by the National Cyber Security Centre (NCSC) on the impact…

On June 5, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published four Frequently Asked Questions (FAQs) regarding Iran-related sanctions under Executive Order 13902 (EO 13902). EO 13902 authorizes the imposition of secondary sanctions targeting the Iranian construction, mining, manufacturing, and textile sectors and persons engaged in “significant transactions” or providing “material support” to parties designated pursuant to the order. Our blog post regarding EO 13902 is available here. The FAQs reconfirm that Iranian manufacturers of medicines,…

The Court of Appeal handed down its judgment in the case of Lamesa Investments Ltd v Cynergy Bank Ltd [2020] EWCA Civ 281 on 30 June 2020. The case appealed a 2019 High Court judgment that found that Cynergy Bank Limited was entitled to refuse to pay interest payments to Lamesa Investments Ltd, under a facility agreement, due to a concern that Cynergy would be subject to US secondary sanctions (please see our previous blog post here). The Court dismissed…