On January 16, 2016, known as “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA), the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License H, which allows foreign subsidiaries of U.S. companies to engage in business with Iran, but with strict limitation on the…
Global Trade & Sanctions Law
FCC Removes Cuba from Exclusion List
On Friday, the Federal Communications Commission (FCC) issued an order making it easier for US telecommunications companies seeking authority to provide services to Cuba. In its order, the FCC removed Cuba from what is known as the Exclusion List, which identifies countries that require separate licensing by the FCC. Typically, the FCC…
Implementation Day Arrives for Iran Sanctions
January 16, 2016 was “Implementation Day” under the Joint Comprehensive Plan of Action (JCPOA), bringing into effect the sanctions commitments of the United States and European Union (EU). The International Atomic Energy Agency (IAEA) confirmed in Vienna that Iran had met its JCPOA milestones with respect to its nuclear program. …
OFAC Rings in the New Year with More Details on its Cyber Sanctions Program
On December 31, 2015, the Office of Foreign Assets Control (OFAC) issued regulations which codify and provide further details on the cybersecurity sanction program introduced on April 1, 2015 under Executive Order (E.O.) 13694. While the Obama administration still has yet to make its first designations under the new program,…
Lifting of 40-Year Statutory Crude Oil Export Ban Signed into Law
On Friday December 18, 2015 the President signed the Consolidated Appropriations Act, 2016, which funds the Federal government through the 2016 fiscal year. Among many other non-funding related provisions, section 101 of Division O of the Act removed the 40-year ban on the export of crude oil. It repeals Section 103…
New U.S. General License Eases Trade with Myanmar
The U.S. Office of Foreign Assets Control (OFAC) issued General License 20 for Myanmar (Burma) on December 7, 2015, which authorizes certain trade related transactions that were previously prohibited due to the role of sanctioned parties in the country’s ports and other trade infrastructure. The U.S. sanctions regime for Myanmar,…
U.S. and EU Ease Belarus-Related Sanctions on Certain Key Individuals and Entities
On October 29, 2015, the U.S. and the EU took separate actions to ease their respective Belarus-related sanctions programs for six months. These measures follow the October 11, 2015 reelection of Alexander Lukashenko as President of Belarus, the regime’s decision to release certain political prisoners and hopes for an improvement…
DOJ Steps Up Wood Imports Enforcement: Lumber Liquidators $13 Million Lacey Act Settlement
Importers of wood products should take note of the Justice Department’s first wood-related criminal conviction under the Lacey Act, which prohibits trade in illegally harvested plants or wildlife, and requires import declarations for certain products. On October 7, 2015, Lumber Liquidators pleaded guilty to five criminal counts, including entry by…
Iran and Adoption Day – What We Learned and What We Did Not
On October 18, 2015, both the United States and the European Union took action to prepare for future changes to sanctions policy which will be effective upon IAEA verification of Iran’s commitments under the Joint Comprehensive Plan of Action (JCPOA). This was a required step under the JCPOA, termed “Adoption…
Pillsbury Luncheon – Doing Business in Russia: Legal Developments and Compliance Considerations for U.S. Companies
Pillsbury and Goltsblat BLP are pleased to announce that Evgeny Shumilov, Economic Attaché, Embassy of the Russian Federation, will be participating in the October 21 luncheon and roundtable discussion on doing business in Russia. Mr. Shumilov will open the event by discussing the state of U.S.-Russia trade and opportunities for…