January - 2019

U.S. issues a new executive order, general licenses and a designation against Venezuela

On 25 January 2019 U.S. President Trump signed an Executive Order entitled “Taking Additional Steps to Address the National Emergency with Respect to Venezuela.” This Executive Order broadens the definition of the term “Government of Venezuela” to include anyone that has acted, or allegedly acted, either directly or indirectly, for or on behalf of the Government of Venezuela, including members of the Maduro regime. Furthermore, on 28 January 2019 the U.S. Department of Treasu

3 companies removed by OFAC from the SDN list

On 27 January 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has removed En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo from its List of Specially Designated Nationals and Blocked Persons (“SDN List”). These three companies have ‘reduced Oleg Deripaska’s direct and indirect shareholding stake . . . and severed his control.’ In addition, En+ Group plc, UC Rusal plc, and JSC EuroSibEnergo have agreed to OFAC’s auditing,

German Customs issues new edition of information leaflet on customs declarations

Germany’s Central Customs Authority (‘Generalzolldirektion’) has issued a new edition of its information leaflet on customs declarations, summary customs declarations and re-export notices (‘Merkblatt zu Zollanmeldungen, summarischen Anmeldungen und Wiederausfuhrmitteilungen’). The new edition has become effective January 1, 2019. It can be found in the general download section for information leaflets on the Central Customs Authority’s website.

Website extracts to be submitted in license applications starting from February

BAFA (‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’), the German export control authority, has informed the public that applicants for export or shipment licenses will have to submit extracts of their buyer’s/ receiver’s’ or the commodities end-user’s websites, respectively, when submitting license applications on or after February 1, 2019. As BAFA notes in its January 10 newsletter 'Exportkontrolle Aktuell', this requirement is conditional on certain circumstances such a

UK encourages businesses to prepare for Brexit

The UK’s HM Revenue & Customs (HMRC) has further encouraged UK businesses to prepare for the UK’s departure from the European Union (EU) on 29 March 2019. The HMRC states, ‘Leaving the EU with a deal remains the Government’s top priority, however the government and businesses should continue to plan for every possible outcome including no deal.’ Specifically, HMRC encourages businesses that trade with the EU to register for an UK Economic Operator Registration and Identificat

OFAC temporarily extends Ukraine-related General Licenses

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has extended the expiration of Ukraine-related General Licenses No. 13J, 14E, and 16E. These three General Licenses relate to EN+ Group PLC, JSC EuroSibEnergo, and United Company RUSAL PLC. To read the announcement by OFAC from 16 January 2019 please click here.

UK updates OGEL to include Qatar as a destination for military goods

The United Kingdom’s Department for International Trade: Export Control Joint Unit (ECJU) has updated its Open General Export Licence (OGEL) for Military Goods: Collaborative Project Typhoon to include Qatar as a destination. This updated OGEL comes into effect on 17 January 2019. To read the notice published by the ECJU please click here.

OFAC not processing License Applications during U.S. Government shutdown

The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) will not be processing applications submitted through their License Application System during the U.S. Government shutdown. OFAC instructs applicants to submit online upon the re-opening of the Federal Government.

U.S. publishes report on the impact of Iranian sanctions

On 4 January 2019 the U.S. Congressional Research Service released its Iran Sanctions report. This report analyzes U.S. and international sanctions against Iran and tracks the “implementation” of the various U.S. laws and Executive Orders and their effect on Iran’s nuclear program, economy, etc. The report summarizes that “sanctions had a substantial effect on Iran’s economy and on some major strategic decisions, but little or no effect on Iran’s regional malign activities.”

Additional Venezuelan sanctions by OFAC

On 8 January 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned seven individuals, 23 companies, and one aircraft (N133JA). Pursuant to Executive Order 13850, these sanctions target individuals (and their assets) who bribed the Venezuelan Office of the National Treasury to conduct illicit foreign exchange operations in Venezuela, and include two former Venezuelan National Treasurers. In addition, OFAC has issued General License No. 6

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