Today, the U.S. Department of Commerce published for comment proposed regulations that would create sweeping authority to oversee, and potentially require the removal of, purchases of foreign telecommunications and IT technology linked to “foreign adversaries” by persons in the United States and U.S. companies overseas. The draft regulations on “Securing the Information and Communications
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New OFAC Guidance On Compliance Programs
By Paul Marquardt & Nathanael Kurcab on
On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control released “A Framework for OFAC Compliance Commitments”, providing general guidance on the elements OFAC considers to compose an effective sanctions compliance program.
Broadly, the framework endorses a risk-based approach to compliance (recognizing that no two compliance programs will…
France, Germany, UK Launch INSTEX to Facilitate Trade With Iran
By Polina Lyadnova, Sujin Chan-Allen & Sarah Haddad on
On January 31, 2019, France, Germany and the UK (the “E3”) announced the creation of the Instrument in Support of Trade Exchanges (“INSTEX”), a special purpose vehicle intended to facilitate legitimate trade between European companies and Iran, registered in France. This initiative is supported by the European Union. The vehicle was created in the wake of the U.S.’ withdrawal in 2018 from the Iran nuclear deal (the Joint Comprehensive Plan of Action (“JCPOA”)), in addition to the EU Blocking Regulation, and as part of the EU’s response to the re-imposition of U.S. secondary sanctions on Iran through the U.S. Executive Order 13846 (the “Executive Order”). The Executive Order re-imposed the secondary sanctions regime against Iran that it have been suspended while it was a party to the JCPOA. …
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