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 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 10, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated Ajay Gupta, Atul Gupta, Rajesh Gupta, and Salim Essa of South Africa (“the Guptas”) as Specially Designated Nationals (“SDNs”). The Guptas and their business associate, Essa, were designated in connection with their involvement in corruption under Executive Order 13818 (EO 13818), which implements and expands upon the sanctions authorities set out in the Global Magnitsky Human Rights Accountability Act. The…
On October 10, 2019, the Department of the Treasury 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 Treasury, the following countries require or may require participation in, or cooperation with, an international boycott: Iraq, Kuwait, Lebanon, Libya,…
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…
On February 6, 2019, 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 Treasury, the following countries require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3)…
On September 26, 2018, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 180910826-8826-01] that amends the Export Administration Regulations (EAR) by adding fourteen entities to the Entity List. These fourteen 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 Entity List under the destinations of Belarus, Iran, Russia, and Singapore.
On 18 July 2018, the Official Journal published Commission Implementing Regulation (EU) 2018/1013 of 17 July 2018 imposing provisional safeguard measures with regard to imports of certain steel products. On 26 March 2018, the Commission published a Notice of Initiation of a safeguard investigation concerning imports of 26 steel product categories (2018/C 111/10) in the Official Journal. The Commission decided to initiate the investigation in the light of sufficient evidence that imports of those products might cause or threaten to cause serious injury to the Union producers concerned. On 28 June, the investigation was extended to two additional product categories. There was also a high risk of further increase of imports resulting from trade diversion due to the measures against imports of steel adopted by the United States under Section 232 of the Trade Expansion Act of 1962 (‘Section 232’). The 28 product categories (‘the product concerned’ or the ‘product categories concerned’) are all covered by the steel surveillance mechanism introduced by the Commission in May 2016. They are also subject to the US tariff measures under Section 232.
On May 16, 2018, the Department of the Treasury published in the Federal Register, in accordance with section 999(a)(3) of the Internal Revenue Code of 1986 (IRC), 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 IRC). On the basis of the best information currently available to Treasury, the following countries require or may require participation in, or…
On March 22, 2018, the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a final rule [Docket No. 180227219-8219-01] (the “Final Rule”) adding, in relevant part, 15 South Sudanese entities to the Export Administration Regulations’ (“EAR”) Entity List — a step that increases the pressure on that country following the US Government’s imposition of an arms embargo last month.