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Trade Sanctions

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On October 20, 2020, US Customs and Border Protection (CBP) published in the Federal Register a general notice [CBP Dec. 20-17] that the Executive Assistant Commissioner, Office of Trade, of CBP with the approval of the Acting Secretary of Homeland Security, has determined, pursuant to 19 U.S.C. 1307 and 19 CFR 12.42(f) that stevia leaf (Stevia rebaudiana) extracts, or glycosides classified under subheading 2938.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), that are mined,…

On October 16, the Department of Commerce’s Bureau of Industry and Security (BIS) announced that exporters can request six-month extensions of export licenses that are set to expire on or before December 31, 2020. According to BIS, this is being done to “cut[] red tape and mak[e] it easier for exporters to drive our Nation’s economic recovery in the wake of the pandemic.” Exporters can request the extension by emailing [email protected] The original license will be…

On 15 October, the EU imposed Designated Party controls on six individuals and one entity in Russia under the EU’s Chemical Weapons sanctions regime for their alleged involvement in the poisoning of Alexei Navalny with a nerve agent in August 2020. The EU separately designated one Russian individual under the Libya sanctions regime, for alleged breaches of the UN arms embargo against Libya. These individuals and entities are now subject to a travel ban and…

The European Council has designated 40 individuals under its Belarus sanctions regime, amending Council Regulation (EC) 765/2006. In the UK, the Office of Financial Sanctions Implementation (OFSI) has accordingly updated the consolidated list. 5 of these individuals were already sanctioned under the UK’s Global Human Rights regime and are now subject to an asset freeze under both the UK and EU regimes. OFSI has also updated information for a further 4 individuals under the UK regime, bringing the…

On 9 October 2020, the Office of Financial Sanctions Implementation (OFSI) published its Annual Review, providing an overview of OFSI’s activities in the financial year April 2019 to March 2020. A copy of the Annual Review is available here. In addition, OFSI has reminded UK businesses that they must report any frozen assets they hold by 16 October 2020. Statistics In 2019-2020, OFSI received 140 reports of potential financial sanctions breaches, an increase from 99 previously. The…

On October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) identified the Iranian financial sector as subject to Executive Order (EO) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many humanitarian transactions and activities will…

On October 13, 2020, the Treasury Department published in the Federal Register a current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986). On the basis of the best information currently available to the Department of the Treasury, the following countries require or may require participation in, or cooperation with, an international boycott: Iraq, Kuwait,…

On September 24, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published a Final Rule in the Federal Resister that amended the Cuban Assets Control Regulations (CACR) to further implement the President’s foreign policy to deny the Cuban regime sources of revenue. Major elements of the changes include: Professional (Including Business) Meetings and Conferences: The Final Rule amends a CACR general license to eliminate the authorization for CACR parties to attend or organize professional (including business)…

In keeping with tradition, we are pleased to invite you to our annual Year-End Review of Import/Export Developments. In lieu of our annual conference in Santa Clara, CA, we are excited to provide a virtual offering available to all our clients and friends worldwide! The conference will be comprised of nine one-hour sessions over the course of three days. Please join us on November 17, 18 and 19 for any or all sessions. To view the full agenda and register click…

On October 1, 2020, the Office of Foreign Assets Control (OFAC), Treasury, published in the Federal Register a final rule amending the Weapons of Mass Destruction Proliferators Sanctions Regulations (WMD Regulations; 31 CFR part 544) to update a note to describe how persons designated pursuant to the WMD Regulations for North Korea-related activities are identified on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List). Specifically, OFAC is amending the note to explain that…