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There Are So Many US Restricted Party Lists, Do I Really Need to Search Them All?

Several circumstances may trigger the need for non-US parties to conduct restricted party screening against the various lists published by the US government.  Deciding whether screening is useful, and which lists to screen against, depends upon the particulars of the business activity or contemplated transaction.  The increasing prevalence of secondary sanctions from the United States makes screening against US lists… … 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

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

Export Controls Enforcement by the Dutch Court | Part 2: The Case of the Airline Company

In our previous post, we discussed the export controls enforcement case brought against a logistics provider. At the same date, the same court also issued a judgment against an airline company that had acted as a carrier of certain military goods. (Rechtbank Noord-Holland, nr. 15/994178-17, 24 April 2017). This second case contains some observations by the Court that are worth highlighting… … Keep Reading

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