90-Day Wind Down Period Expires; First Wave of US Secondary Sanctions Against Iran Re-Imposed
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
While EU countries reaffirm their commitment to the JCPOA, EU companies brace for impact
Although expected, President Trump’s decision to pull the US out of the JCPOA has triggered swift and concerned reactions from Europe. Despite the EU’s reaffirmed commitment to the JCPOA, it is yet unclear whether – and how – the Agreement will survive. … Keep Reading
They’re Back: US Nuclear Sanctions against Iran
United States is pulling out of the Joint Comprehensive Plan of Action (“JCPOA”). What does this mean going forward? … Keep Reading
Meet OFAC in Brussels and discuss the disruption of export control & sanction regimes by new technologies on 11 June 2018
The combination of innovation and digitization causes severe disruption to existing controls and regimes. New technologies have potential to disrupt if not evade traditional export control regimes and create significant challenges for businesses and regulators alike. … Keep Reading
Belgian companies brought to Court for illegal exports of chemicals to Syria
The Belgian customs authorities are suing three Belgian companies before the Criminal Court of Antwerp for what appears to be serious infringements of the restrictive measures imposed on Syria. The three companies concerned are all parties involved in the supply chain of a deal in chemical products: the producer, the company handling the administrative aspects of the transaction, and the… … Keep Reading
EU Commission issues notice to stakeholders on impact of Brexit
On 25 January 2018, the EU Commission issued a notice regarding the impact of Brexit on future movements of controlled goods. By Olivier Coulon, 26 January 2018 In its notice, the EU Commission recalls that, unless an agreement would provide for another date, the United Kingdom shall be treated as a third country as from 30 March 2019. The impact… … Keep Reading
Shipping Criminal Liability: the Difficult Position of the Transportation & Logistics Sector
On 23 November 2017, the Court of Amsterdam handed down its decisions in the case concerning the Dutch transportation company charged with breaching the military embargo against the Russian Federation. These decisions are the latest in a string of Dutch enforcement cases relating to the transit of military goods which have raised concerns within the transportation & logistics sector. In… … Keep Reading
Export Control Considerations: Beyond the Authorization
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