December - 2019

UK House of Commons passes the 2nd reading of the European Union (Withdrawal Agreement) Bill

On 19th December 2019, the Members of Parliament (MPs) of the United Kingdom’s House of Commons passed the second reading of the European Union (Withdrawal Agreement) Bill 2019-20. The Bill is scheduled to proceed to a Committee of the whole House of Commons on the 6th and 7th of January 2020. Please follow this link to read the news release about about the second reading results.

U.S. President signs bill authorizing sanctions against Nord Stream 2

On 20th December 2019, the U.S. President signed S. 1790, the “National Defense Authorization Act for Fiscal Year 2020,” into law. Section 7503 of S. 1790, entitled “Protecting Europe’s Energy Security Act of 2019,” authorizes sanctions against vessels laying pipe at 100 feet or more below sea level for the Nord Stream 2 pipeline project and the TurkStream pipeline project (see previous post). The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has i

German customs publishes new leaflet

On 17th December 2019, German customs (Generalzolldirektion, "Zoll") published a new leaflet entitled "Merkblatt zu Zollanmeldungen, summarischen Anmeldungen und Wiederausfuhrmitteilungen" (“Leaflet on customs declarations, summary declarations and re-export notifications”). This leaflet is available for download and valid starting 1st January 2020. Changes within the leaflet are shown in italics.

OFAC amends Iran-related General License and Frequently Asked Questions

On 19th December 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended Iran General License (No. K-1) entitled “Authorizing Maintenance or Wind Down of Transactions Involving COSCO Shipping Tanker (Dalian) Co., Ltd.” OFAC also amended three related Frequently Asked Questions (FAQs), 804, 806, and 807. Please follow this link to read the OFAC announcement.

UK OFSI publishes blog about determining if you are dealing with a sanctioned entity

On 17th December 2019, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) published a blog entitled “Am I dealing with a sanctioned entity?”. The article explains how to find out if an individual or company is subject to financial sanctions, giving examples of how complex company ownership structures can mask sanctioned entities. OFSI offers the Libya Africa Investment Portfolio (LAIP) as a case study and outlines steps to take if you believe you are dea

New U.S. DOJ voluntary self-disclosure policy

On 13th December 2019, the U.S. Department of Justice (DOJ) announced a revised policy for business organizations voluntarily disclosing export control and sanctions violations. The Voluntary Self-Disclosure Policy, or VSD Policy, encourages companies to voluntarily self-disclose potential violations of main U.S. export control and sanction regimes, namely, the Arms Export Control Act (AECA), 22 U.S.C. § 2778, the Export Control Reform Act (ECRA), 50 U.S.C. § 4801 et seq., an

OFAC updates its Frequently Asked Questions and SDN list

On 13th December 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) added three new Frequently Asked Questions (FAQs). FAQs 812-814 address the specific constraints on U.S. persons engaged in transactions (including artwork transactions) with persons designated as Specially Designated Global Terrorists (SDGTs) or persons blocked pursuant to Executive Order 13224 (E.O. 13224). Furthermore, OFAC updated its SDN list. Please follow this link to r

U.S. House of Representatives approves sanctions against Nord Stream 2 and other gas pipeline projec

The U.S. House of Representatives has approved House Report H. Rept. 116-333 which is related to the National Defense Authorization Act for Fiscal Year 2020 (Senate Bill S. 1790). As stated in a press release by Senator Ted Cruz, the House report includes Senate Bill S. 1441, also known as the Protecting Europe’s Energy Security Act of 2019 (In the House report, this part is printed on pp. 1118–1123). Bill S. 1441 sets up sanctions provisions against the Nord Stream 2 gas pip

PST.AG attended BAFA’s Export Control Information Day in Frankfurt am Main

On 11 December 2019 Germany’s ‘Bundesamt für Wirtschaft und Ausfuhrkontrolle’ (BAFA) hosted the ‘11. Informationstag Exportkontrolle’ (11th Export Control Information Day) in Frankfurt am Main. Topics discussed at the event included the status of the current reform of the EU Dual-Use Regulation (Council Regulation (EC) No 428/2009), current legal developments with regard to the export of military goods as well as planned changes to the BAFA process for issuing export licenses

OFAC publishes two new Frequently Asked Questions on Iran sanctions

On 11 December 2019 the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on its website answered two new Iran-related Frequently Asked Questions (FAQs). The two new FAQs relate to the legal impact of the sanctions designations against the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited.

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