Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML) Directive, 2015/849 (the “Directive”) that would implement new rules to combat money-laundering, terrorism financing and tax evasion. The…
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“Buy American, Hire American”—From Rhetoric to Regulation
“We will follow two simple rules: buy American and hire American.” While world leaders are pondering what these words from President Trump’s Inaugural Address mean for international trade, a different question looms for U.S. Government contractors—what is on the horizon as far as the Buy American Act and similar protectionist…
General License for Commercial Authorizations from Sanctioned Russian Security Agency
OFAC has issued a new General License to address problems raised by the sanctioning of the Federal Security Services (FSB). This adjustment serves to authorize permits by the FSB needed for certain commercial transactions and is a limited exception to the sanctions listing of the FSB on December 28, 2016…
US Terminates Arms Embargo Policy for Vietnam
On May 23, 2016, during President Obama’s visit to Ho Chi Minh City, the United States announced the termination its long-standing arms embargo policy for Vietnam. Exports of defense articles and defense services to Vietnam will still require a license, but the Directorate of Defense Trade Controls (DDTC) will now…
Piercing the bitcoin veil: Businesses should beware the risks of trading with a sanctioned entity
In January the EU and the US lifted economic and financial sanctions against Iran in a ground-breaking deal that unfroze billions of pounds of assets and opened up new markets for the first time since 2010. Despite the fanfare surrounding the deal, in the small print a warning remains: some…
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. …
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…