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Trade Sanctions

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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 January 3, 2020, the Federal Communications Commission (FCC) published in the Federal Register a document [WC Docket No. 18–89; FCC 19–121; FRS 16316] seeking comment on actions to address national security threats to networks funded by the Universal Service Fund (USF). The FCC concurrently adopted a Report and Order addressing the use of USF support to purchase or obtain any equipment or services produced or provided by a covered company posing a national security…

On January 3, 2020, the Federal Communications Commission (FCC) published in the Federal Register a final rule [WC Docket No. 18–89, PS Docket Nos. 19– 351, 19–352; FCC 19–121; FRS 16315], effective on publication, that prospectively prohibits the use of Universal Service Fund (USF) funds to purchase or obtain any equipment or services produced or provided by a covered company posing a national security threat to the integrity of communications networks or the communications supply…

On December 23, 2019, the Commerce Department published in the Federal Register a document [Docket No. 191217-0118] extending the comment period for a proposed rule to implement regulations pursuant to Executive order 13873 of May 15, 2019, entitled “Securing the Information and Communications Technology and Services Supply Chain.” On November 27, 2019, Commerce published a proposed rule to implement regulations that would govern the process and procedures that the Secretary of Commerce will use 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 16 December 2019, the Russian Government signed Resolution No. 1685, which expanded an import ban with respect to Ukrainian goods. The list of banned goods initially introduced by Resolution of the Russian Government No. 1716-83 dated 29 December 2018 now includes cornstarch, glucose and fructose, a number of medical goods (such as medical stoppers, hot-water bags, ball syringes), radiators, central-heating boilers and waste paper. These goods are prohibited from entering Russia if they (i) originate from Ukraine, (ii) are supplied from Ukraine, or (iii) have…

On November 26, 2019, the US Department of Commerce (Commerce) issued a highly anticipated proposed rule with proposed regulations (“Proposed Regulations”) to implement Executive Order 13873, “Securing the Information and Communications Technology and Services Supply Chain” (Executive Order 13873). Executive Order 13873 gives the Secretary of Commerce (“Secretary”) sweeping, unprecedented authority to prevent or modify transactions involving information and communications technology and services (“ICTS”) originating in countries designated as “foreign adversaries” which pose an undue risk to…

On November 27, 2019, President Trump signed two bills into law that increase US sanctions and export control restrictions as they relate to China. The bills, approved in response to recent political protests in Hong Kong, had near unanimous support from the US Congress. President Trump previously expressed concerns about the legislation while in the midst of negotiating a trade deal with China but ultimately signed both bills in the hopes that the “Leaders and…