As reported in our earlier post, as part of the US Government’s announcement that the United States was exiting the Joint Comprehensive Plan of Action (“JCPOA”), the US set out separate 90-day and 180-day time frames for the wind down of activities consistent with the sanctions relief in the JCPOA, following which the secondary sanctions lifted pursuant to the JCPOA… Keep Reading
Your compliance obligations don’t end once an authorization is in hand. Determining whether and what authorizations are needed and ensuring that all required authorizations have been obtained are critical first steps in trade compliance, but compliance is a continuing process. By Megan Barnhill, Bryan Cave LLP, 8 December 2017 Review and Understand the Authorization A critical first step is to… Keep Reading
After a number of tweets and news articles indicating that President Trump intended to make major changes to U.S. policy regarding Iran, President Trump formally announced on Friday, October 13, his Administration’s strategy on the subject. The strategy announcement itself resulted in limited changes to U.S. sanctions and no change (for now) with respect to the role of the United… Keep Reading
As discussed in our previous post, the report published earlier this year by the EASME regarding the dual-use potential of certain Key Enabling Technologies (KETs) highlights the importance for companies in this area to be aware of the possibility of such technologies being or becoming subject to control under the EU Dual Use Regulation. By Megan Gajewski Barnhill & Roland… Keep Reading
Deespite changes in 2016 to the U.S. and E.U. sanctions against Iran, “issuers” registered under the U.S. securities laws should remember that certain reporting requirements continue to apply. Keep Reading
While there was some discussion in the EU about possible lifting of some or all of the sanctions against Russia earlier this summer, the US Government is continuing to expand its sanctions against Russia that it commenced in March 2014 in response to Russia’s alleged involvement in the Crimean region of Ukraine. By Megan Gajewski Barnhill, 27 September 2016 The… Keep Reading
In the wake of eased sanctions against Iran, companies operating in Europe may wish to take advantage of new opportunities involving Iran, including having employees travel to Iran to explore such opportunities. However, having employees engage in such travel gives rise to considerations under the US Visa Waiver Program should the employee subsequently travel to the United States. By Megan… Keep Reading
Much attention has been paid as of late to the sanctions relief granted to Iran arising out of the Joint Comprehensive Plan of Action (JCPOA) among the United States and its partners in the P5 + 1 (China, France, Germany, Russia, and the United Kingdom). Although US sanctions relief remains limited, General License H authorizes non-US subsidiaries of US companies… Keep Reading