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Trade Sanctions

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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…

On October 21, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to further restrict exports and reexports of items to Cuba (“the Amendment“). According to BIS, the Amendment was made to further restrict the Cuban government’s access to items subject to the EAR, thereby supporting the US government’s national security and foreign policy decision to hold the Cuban regime accountable for its repression of the Cuban people…

October 30, 2019 by Nicholas F. Coward, Alexandre (Alex) Lamy and Meghan Hamilton On October 17, 2019, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and amended as General License No. 13D (“GL 13D”) to continue the validity period for transactions concerning Nynas AB and its affiliates (“Nynas”), as further described below. In addition, on October 21, 2019, OFAC re-issued as General License No. 8D (“GL 8D”) to continue the validity period certain maintenance activities involving Petróleos de Venezuela S.A. (“PdVSA”)…

On October 23, 2019, the US Treasury Department Office of Foreign Assets Control (OFAC) announced that it had deleted two Turkish ministries and three Turkish individuals from the list of Specially Designated Nationals and Blocked Persons (“SDN List”). These five parties had been designated to the SDN List on October 14, 2019 pursuant to Executive Order 13894 (EO 13894) for contributing to Turkey’s military offensive in northern Syria. Please see our blog post regarding EO 13894 here. OFAC’s…

On October 14, 2019, President Trump released a statement that said that he would be “issuing an Executive Order authorizing the imposition of sanctions against current and former officials of the Government of Turkey and any persons contributing to Turkey’s destabilizing actions in northeast Syria.” He also said the steel tariffs will be increased back up to 50 percent, the level prior to reduction to 25% in May. The United States will also immediately stop…

On October 9, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) added 28 Chinese entities to the Entity List because they are accused by the US Government of being associated with human rights violations and abuses against Uighurs, Kazakhs, and other members of Muslim minority groups in the Xinijiang Uighur Autonomous Region (XUAR). All exports, reexports, or in-country transfers of items (i.e., goods, software, technology) subject to the Export Administration Regulations (EAR),…

On 14 October 2019, the Dutch government announced that on 11 October 2019, the government decided, in response to the Turkish invasion of northern Syria, to tighten Dutch arms export policy with regard to Turkey. Until further notice, all new license applications for the export of military goods to Turkey will be held and no new licenses will be issued. Other EU partners, such as France, Germany, Sweden, Finland, Norway and Belgium, have also tightened their national…

On 14 October 2019, the Council of the EU announced that it has extended restrictive measures by the EU addressing the use and proliferation of chemical weapons until 16 October 2020. These sanctions, which consist of a travel ban to the EU and an asset freeze for persons, as well as an asset freeze for entities, currently apply to nine persons – five linked to the Syrian regime and four involved in the Salisbury attack…

On 14 October 2019, the Council of the European Union announced that it adopted a framework for targeted restrictive measures in view of the situation in Nicaragua. The press release stated: This framework provides for the possibility of imposing targeted and individual sanctions against persons and entities responsible for human rights violations or abuses or for the repression of civil society and democratic opposition in Nicaragua, as well as persons and entities whose actions, policies…

On September 30, 2019, the Office of Foreign Assets Control (OFAC) amended two Venezuela-related general licenses (GLs), re-issued as General License 3G (GL 3G) and General License 9F (GL 9F), to extend the authorization for dealings in certain bonds and other securities, as further outlined below. Our blog post regarding previous amendments to these GLs is available here. GL 3G was amended to extend the validity period of the authorization for transactions and activities that are ordinarily incident and necessary…