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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, it will be one to watch in 2016 given the high profile and geo-political challenges of cybercrime.

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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 of the Energy Policy and Conservation Act (42 U.S.C. § 6212), the cornerstone of the prohibition on exporting crude, and provides that “[n]otwithstanding any other provision of law … no official of the Federal Government shall impose or enforce any restriction on the export of crude oil.”

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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.

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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 of the political and economic relationship between Western countries and Belarus. While currently temporary in nature, the sanctions relief provided affords Western companies opportunities to engage in certain transactions in Belarus.

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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 means of false statements, transport of illegally imported timber, and import of illegally harvested timber.  In a recent client alert, William Sullivan, Jr., and Benjamin Cote discuss the implications of the plea agreement’s onerous compliance requirements for interpreting the scope of the Lacey Act’s “due care” requirement, and the potential implications for companies wishing to avoid violations.

Client Alert:  Lacey Act Lessons From The Lumber Liquidators $13 Million Settlement: Has The Definition Of “Due Care” Been Expanded? [client alert link]

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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 Day,” scheduled to occur ninety (90) days after the JCPOA was endorsed by the UN Security Council via resolution 2231.

Importantly, Adoption Day does not bring about any immediate sanctions relief.  OFAC reminded companies again about potential violations related to arranging agreements and contingent contracts with Iranian parties prior to Implementation Day.

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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 U.S. companies in the Russian market.

Please join us for Mr. Shumilov’s remarks and for presentations from top legal minds from Pillsbury and Goltsblat BLP regarding the key developments under Russian, U.S. and EU laws and regulations for U.S. companies doing business in Russia today.

Topics include:

  • Russian Legal Developments: Major recent Russian legislative developments and initiatives, including changes to employment, real estate, commercial, anti-trust, corporate and tax laws.
  • U.S. and EU Sanctions Update: Current compliance considerations for U.S. companies and their subsidiaries and affiliates doing or seeking to do business in Russia.
  • News from Capitol Hill: Outlook for U.S.-Russia relations through the November 2016 elections.

Speakers

Evgeny Shumilov, Economic Attaché, Embassy of the Russian Federation

Andrey Goltsblat, Managing Partner, Goltsblat BLP

Nancy Fischer, Partner, Pillsbury

The Honorable Gregory H. Laughlin, Senior Counsel, Pillsbury

Elina Teplinsky, Partner, Pillsbury

 

For questions or to register, please contact Julie Merkin at julie.merkin@pillsburylaw.com.

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On October 5, the trade ministers of the 12 nations participating in the negotiations announced that they had successfully concluded the Trans-Pacific Partnership (TPP) free trade agreement. Australia, Brunei Darussalam, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, United States, and Vietnam are the member countries. There is a long way to go before the TPP is ratified and implemented (and the prospects for ratification in certain countries are not certain), but the agreement represents a major accomplishment for negotiations that began in 2009.

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On Monday, September 21, 2015, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) took coordinated action to further ease U.S. restrictions on trade with Cuba and Cuban nationals.

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Under the terms of the Iran Nuclear Agreement Review Act, Congress had until September 18 to reject President Obama’s promised sanctions relief for Iran agreed to under the Joint Comprehensive Plan of Action (JCPOA). Although the House of Representatives voted to reject the deal, Senate Democrats blocked debate on a similar resolution, thus preventing a vote in the Senate. Consequently, Congress took no action, which means that the JCPOA will continue to be implemented on a step-by-step basis (see our blog post here for full details).  Looking ahead, there are several key issues for businesses contemplating entering the Iran market to consider.

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