October - 2019

U.S. sentences man to prison for exporting goods to Iran

On 24 October 2019 the U.S. Department of Justice issued a press release announcing that the U.S. District Court sentenced Behrooz Behroozian, of Columbus, Ohio, to 20 months in prison for illegally exporting dual-use gas and oil pipeline parts to Iran. For approximately a decade Behroozian exported manifolds, valves and connectors to Iran via an intermediary company, Sumar Industrial Equipment, violating the Emergency Economic Powers Act (IEEPA). Behroozian was also the owne

German customs gives advanced notification in case of ‘no deal’ Brexit

On 23 October 2019 German customs (Generalzolldirektion, "Zoll") published an informational PDF (in German) entitled “ATLAS/AES: impact of an unregulated Brexit” (ATLAS/AES gesamt: Auswirkungen bei einem ungeregelten Brexit, ATLAS-Info 3484/19). This document highlights key events and deadlines in the case that the United Kingdom leaves the European Union without a deal on 31 October 2019. From 1 November 2019 at 00:00 until 09:00 (CET), online systems for German customs will

BIS increases restrictions towards Cuba

The U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announces that it will further restrict exports and reexports of items to Cuba. Effective 21 October 2019, BIS adopts a general policy of denial for all applications to lease aircraft, subject to BIS jurisdiction, to Cuban state-owned airlines, and revokes existing licenses. Additionally, BIS amends the Export Administration Regulations (EAR) to establish a general 10-percent de minimis level for Cuba, me

European Commission updates dual-use export control list

On 17 October 2019 the European 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 majority of changes result from amendments agreed at the Wassenaar Arrangement, although there are some changes resulting from amendments agreed at the Missile Technology Control Regime. If the Council and the European Parliament do not raise any objections to the Commission Delegated Regulation, it

Council of the EU adopts legal framework for sanctions against Nicaragua

On 14 October 2019 the Council of the European Union announced in a press release that it has adopted a legal framework allowing for sanctions against Nicaragua. Persons and entities responsible for human rights violations or abuses, or those suppressing civil society and democracy in Nicaragua are targeted. The sanctions consist of an EU travel ban and an asset freeze for individuals and entities. Additionally, EU persons and entities are not allowed to make funds available

U.S. imposes additional duties on large civil aircraft products from the EU

Effective 18 October 2019, the U.S Trade Representative will impose additional duties on products of certain member States of the EU. These additional duties are a result of the U.S. Trade Representative's determination that the EU and certain member States have “denied U.S. rights under the World Trade Organization (WTO) Agreement and have failed to implement WTO Dispute Settlement Body recommendations concerning certain subsidies to the EU large civil aircraft industry.” Th

U.S. issues a new executive order and general licenses against Turkey for contributing to the situat

On 14 October 2019 U.S. President Trump signed an Executive Order (E.O.) entitled “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.” Under the authority of this E.O., the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has added three individuals and two entities to its list of Specially Designated Nationals and Blocked Persons (“SDN” list). Please note that the associated tag in the data is SYRIA-EO. OFAC

European Commission publishes notice on the application of pan-Euro-Mediterranean preferential rules

On 4 October 2019 the European Commission published the “Commission notice concerning the application of the Regional Convention on pan-Euro-Mediterranean preferential rules of origin or the protocols on rules of origin providing for diagonal cumulation between the Contracting Parties to this Convention” (2019/C 333/03) in the Official Journal of the European Union. This notice replaces notice 2019/C 158/06.

UK amends export control order

On 5 September 2019 the United Kingdom made the Export Control (Sanctions) (Amendment) Order 2019. This order was laid before Parliament on 9 September 2019 and came into force 22 days later (1 October 2019). In this order various subordinate legislation was amended and provisions were made in connection with trade restrictions. More specifically: Eritrea was added to Part 4 of Schedule 4 of the Export Control Order 2008 (S.I. 2008/3231). definitions were updated and amendmen

BIS adds 28 entities to the Entity List

On 9 October 2019 the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 28 entities to the Entity List (15 CFR, Subchapter C, part 744, Supplement No. 4). The Entity List “identifies entities reasonably believed to be involved, or to pose a significant risk of being or becoming involved, in activities contrary to the national security or foreign policy interests of the United States.” Entities on the Entity List have additional license requirements and

1

2