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
Dutch Prosecutor Demands 80.000 Euro Fine in New Sanctions Enforcement Case
On 9 November 2017 another case concerning the breach of sanctions was brought before the Dutch court. This case is the latest example of an increased enforcement effort of the Dutch authorities. From the information published on the government website, it appears that the public prosecution (the Prosecution) has demanded that a logistics provider (the Defendant) will be fined an… … Keep Reading
Trump Administration Unveils Strategy on Iran
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
Change is Coming: China Proposes New Export Control Law
On June 16, 2017, China’s Ministry of Commerce (“MOFCOM”) released for public comments the draft Export Control Law of the People’s Republic of China (the “ECL”). The ECL, once enacted, could substantially change China’s current export controls regime and affect the business operations of EU and U.S. multinationals within and outside of China. By David Stepp, Clif Burns & Zhiwei… … Keep Reading
Two-Year Prison Sentence Demanded in Dutch Sanctions Enforcement Case
Another case that seems to betray a tougher line of sanctions enforcement in the Netherlands has emerged. On 21 August 2017, the Dutch public prosecution (the Prosecution) demanded two years of imprisonment for a managing director of a Dutch company which had dealings with Iran (the Defendant). In this case, brought before the Court of Den Bosch, the Prosecution has… … Keep Reading
EU Commission and Member States to fight any extraterritorial application of the new US sanctions
What about the extra-territorial application of the sanctions in the “Countering America’s Adversaries Through Sanctions Act” (CAATS) signed by President Trump on 2 August 2017? … Keep Reading
Much Ado About Sanctions in the United States
The Countering America’s Adversaries Through Sanctions Act (the CAATS Act) of August 2, 2017 impacts sanctions related to Russia, Iran and North Korea. Key among the changes is that it takes discretion out of the hands of the U.S. President to lift or change certain existing sanctions, particularly the sectoral sanctions imposed against Russia. … Keep Reading
The Restrictive Measures Against Qatar: Watch Closely …
The unprecedented restrictive measures which Saudi Arabia, the U.A.E., Bahrain, and Egypt have imposed on Qatar last month could pose a greater challenge to international business than you might expect. The measures are difficult to navigate, making their scope opaque. Once you have taken the trouble to familiarize yourself with the activities that are being targeted, it will become clear… … Keep Reading