The European Commission updates the EU Control List of Dual-Use Items

On 26 September 2017, the European Commission (the “Commission“) adopted the annual delegated regulation that updates the EU dual-use export control list in Annex I to Regulation (EC) No 428/2009 (the “Dual-use Regulation“) and brings it in line with the decisions taken within the EU framework of the international non-proliferation regimes and export control arrangements in 2016. A major amendment to the Dual-use Regulation is currently expected in 2018. Should you wish to have more information on this topic, please contact … Continued

OFAC sanctions banks and representatives linked to North Korean financial networks

On 26 September 2017, the United States (“US“) Office of Foreign Assets Control (“OFAC“) designated eight North Korean banks and 26 individuals, who are linked to North Korean financial networks. According to OFAC, the designations follow in response to North Korea’s ongoing development of weapons of mass destruction and continued violations of United Nations Security Council Resolutions. The designated individuals are North Korean nationals who are operating in China, Russia, Libya and the United Arab Emirates and who are considered … Continued

Cartier to pay USD334,800 for violating the US sanctions regime

On 26 September 2017, Richemont North America Inc., d.b.a. Cartier (“Cartier“), agreed to pay USD334,800 for violating the Foreign Narcotics Kingpin Sanctions Regulations. Cartier violated the US sanctions between October 2010 and April 2011, when it exported four shipments of jewellery to Shuen Wai Holding Limited in Hong Kong, an entity added to added to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) by the Office of Foreign Asset Control (“OFAC“) in November 2008. According to OFAC, Cartier did not … Continued

Iran unveils new ballistic missile in response to President Trumps UN speech

On 22 September 2017, Iranian President Hassan Rouhani said that Iran will continue to build up its ballistic missile program and other capabilities, unveiling a new ballistic missile capable of carrying multiple warheads for up to 2000 kilometers. President Rouhani’s statement comes just days after United States (“US“) President Trump his first speech to the United Nations, denouncing the Iran nuclear deal and calling it an embarrassment to the US. The Joint Comprehensive Plan of Action requires Iran to comply … Continued

US imposes new sanctions against North Korea

On 21 September 2017, President Trump issued a new Executive Order (“E.O.“) imposing new sanctions on North Korea, in response to its latest nuclear and ballistic missile tests. The new restrictive measures target individuals and entities that engage in trade with North Korea, as well as the financial institutions that facilitate this trade and these measures include: A 180-day ban on vessels and aircraft that have visited North Korea from visiting the United States (“US“). This ban also targets vessels that … Continued

EU extends and updates its Russia and Ukraine sanctions regime

on 14 September 2017, the EU extended its Russia and Ukraine sanctions regime for a period of six months until 15 March 2018. The EU also updated the said sanctions regime, adding Crimean Sea Ports to its list of designated people and entities, including a derogation for payments to Crimean Sea Ports for certain services to the restrictive measures currently in place, and also updating the list of persons subject to these restrictive measures by removing deceased persons from this list. … Continued

US keeps JCPOA in place, while imposing new sanctions against Iran

On 14 September 2017, the United States (“US“) certified Iran’s compliance with its obligations under the Joint Comprehensive Plan of Action (“JCPOA“). Thereby extending the sanctions relief under the JCPOA. Meanwhile, OFAC imposed new sanctions against 11 firms and individuals for allegedly aiding Iran’s ballistic missile program and helping it to conduct cyber attacks on the US and support terrorism. The full OFAC Iran designations can be found here. B&A Law advises many companies interested in or doing business in Iran. … Continued

Vacature advocaat-medewerker sanctierecht en exportcontrole

B&A Law is op zoek naar een gedreven en ambitieuze advocaat-medewerker. Heb jij de kennis en expertise om complexe (grensoverschrijdende) zaken te behandelen? Ben je zelfstandig, een harde werker en ben je positief ingesteld? Dan zijn wij op zoek naar jou. Over jou Onze ideale kandidaat heeft vier tot zes jaren werkervaring als advocaat bij een (groot) advocatenkantoor. Is iemand met kennis van het sanctierecht en de exportcontrole wetgeving, hij of zij heeft een scherp analytisch vermogen en beschikt over … Continued

Trump signs new Russia sanctions

On 2 August 2017, President Trump signed new sanctions against Russia. After approval by the Senate and the House of Representatives, on which we wrote before (see here and here), the sign-off was the last step prior to the entry into force of the new sanctions. As described in our previous posts, the bill introduces a Congressional approval procedure before any waiver, suspension, reduction, relief from, or other limitation of the application of sanctions with respect to the Russian Federation. Also, … Continued