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Trade Sanctions

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On June 20, 2019, the Russian Prime Minister signed Resolution No. 787-31, introducing changes to Governmental Decree No. 1716-83 dated December 29, 2018 that implemented an import ban with respect to Ukrainian goods (please refer to our previous blog posts of January 18, 2019 and April 23, 2019). Per the changes adopted by Resolution No. 787-31: 1) The import ban does not apply to goods imported to complete customs procedures for processing outside the customs territory and temporary…

On Tuesday, June 4, 2019, the Trump Administration announced additional changes to its Cuba policy, further restricting group people-to-people educational travel and limiting the types of aircraft and vessels authorized to travel to Cuba on temporary sojourn. Tuesday’s actions are intended to prevent travel from the United States to Cuba from enriching the Cuban military, intelligence, and security services. These changes, which took effect on June 5, 2019, are a further step toward implementation of…

The Ministry of Commerce of China (MOFCOM) announced on 31 May 2019 that the Chinese government will introduce an “Unreliable Entity List” regime, under which foreign entities or individuals that boycott or cut off supplies to Chinese companies for non-commercial purposes and causing serious damages to Chinese companies would be listed as “Unreliable Entities”. The specific rules, including the list itself and the restrictive measures applicable to the listed entities, will be separately released in…

On May 30, 2019, President Trump announced that, beginning on June 10, 2019, the United States will impose additional duties on all articles imported into the United States from Mexico (via land, sea or air) on an escalating schedule until Mexico does more to stop the flow of illegal migrants to the United States. This tweet was then followed by a longer statement issued by the White House (available here). That statement accuses Mexico of…

On 21 May 2019, the Belgian Act of 2 May 2019 (Numac : 2019012449) including various financial provisions was published in the Belgian Official Gazette. Title VII The aforementioned act contains a Title VII, implementing the EU Blocking Regulation 2271/96 in Belgium. Under the EU Blocking Regulation, the EU operators are in principle prohibited from complying with the (U.S. Iran – Cuba) sanctions, as specified in its annex. They can, however, be authorised to comply…

Effective May 20, 2019, the US Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule creating a 90-day Temporary General License (TGL) authorizing certain transactions involving the export, reexport, and transfer of items subject to the Export Administration Regulations (EAR) to Chinese-headquartered Huawei Technologies Co. Ltd. (“Huawei”) and its sixty-eight non-US affiliates, which were added to the BIS Entity List effective May 16, 2019 (the “Entity List designation”). The TGL will be effective through August 19,…

On May 8, 2019, President Trump issued Executive Order 13871 (the “Iran Metals EO”) imposing sanctions on the iron, steel, aluminum, and cooper sectors of Iran subject to a 90-day wind-down period that will expire on August 6, 2019. Although the sale, supply or transfer to/from Iran of steel and aluminum is already targeted by Section 1245 of the Iran Freedom and Counter-Proliferation Act of 2012, the Iran Metals EO expands upon those sanctions and further targets…

The High Representative of the European Union and the Foreign Ministers of France, Germany and the United Kingdom released a joint statement today (see here for the full statement) following Iran’s announcement yesterday that it would withdraw from certain commitments as agreed as part of the 2015 nuclear agreement (see our post here on this). The statement urged Iran to continue to implement its commitments under the nuclear agreement, stating that Iran’s compliance would be…

President Hassan Rouhani has announced that Iran will withdraw from certain commitments agreed in the 2015 nuclear agreement; this announcement comes a year after the agreement was abandoned by the US, leading to the re-imposition of US sanctions against Iran. In his 8 May 2019 announcement, Hassan Rouhani declared that Iran will stop exporting its surplus enriched uranium. This decision is contrary to the agreement, under which Iran is required to sell its surplus enriched…

On May 14, 2019, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 181219999-8999-01] that amends the Export Administration Regulations (EAR) by adding twelve entities, under a total of sixteen entries, to the Entity List. These twelve entities have been determined by the US Government to be acting contrary to the national security or foreign policy interests of the United States and will be listed on the…