May - 2020

U.S. revises sanctions against Iraq and Zimbabwe

On 21st May 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it is amending the Zimbabwe Sanctions Regulations (31 C.F.R. part 541). This amendment is effective from 22nd May 2020. Furthermore, a statement from the U.S. White House on 20th May 2020 announced that the national emergency with respect to the stabilization of Iraq declared in Executive Order 13303 will be continued for one year.

OFAC recent actions: Iran nuclear-related waiver and shipping guidance

On 27th May 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a new Frequently Asked Question regarding the ending of certain Iran nuclear-related waivers following a statement by the Secretary of State. OFAC simultaneously announced the addition of two Iranians to the SDN list. Additionally, on 14th May 2020 OFAC announced that together with the U.S. Department of State and the U.S. Coast Guard they have issued an advisory on methods

EU export restrictions on personal protective equipment not extended

The end date of EU Regulation 2020/568 (reported on here), which introduced an obligation to submit a license for the export of personal protective equipment, has not been extended. The regulation, which entered into force on 26 April 2020, was valid for 30 days. Therefore, the relevant approval requirements of EU Regulation 2020/568 are no longer applicable. To read the report from Germany’s “Bundesamt für Wirtschaft und Ausfuhrkontrolle” (BAFA), please follow this link.

U.S. further restricts Huawei exports and extends temporary general license

On 15th May 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced that it will further restrict Huawei’s “ability to use U.S. technology and software to design and manufacture its semiconductors abroad.” Specifically, the following foreign-produced items will be subject to the Export Administration Regulations (EAR): (i) Semiconductor designs by Huawei and its affiliates on the Entity List, that are direct products of U.S. Commerce Control Li

European Commission imposes additional customs duties on EU imports originating in the US

Effective 8th May 2020, the European Commission has implemented regulation 2020/502 of 6 April 2020 on “certain commercial policy measures concerning certain products originating in the United States of America.” As retaliation for tariff increases by the United States on imports of certain derivative aluminum and steel products, the European Commission has given an additional ad valorem duty of 20% to CN code 9613 80 00 and an additional ad valorem duty of 7% to CN code 3926

European Commission publishes coronavirus-related guidance regarding humanitarian aid

On 12th May 2020, the European Commission announced that it has published guidance on how coronavirus-related humanitarian aid can be sent to countries and regions that are subject to EU sanctions. This guidance note is in a question/answer format and the first version covers humanitarian aid to and sanctions against Syria.

OFAC removes Venezuela-related General License 13E involving Nynas AB

On 12th May 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) revoked Venezuela-related General License (GL) 13E “Authorizing Certain Activities Involving Nynas AB.” In addition, OFAC issued GLs 3H (“Authorizing Transactions Related to, Provision of Financing for, and Other Dealings in Certain Bonds”) and 9G (“Authorizing Transactions Related to Dealings in Certain Securities”) to remove references to Nynas AB. OFAC also updated its Frequentl

BAFA publishes new overview of country-specific embargoes

As of 28 April 2020, Germany’s “Bundesamt für Wirtschaft und Ausfuhrkontrolle” (BAFA) has published a new overview of country-specific embargoes (rubric is available for download here). According to BAFA, these embargoes are for foreign or security policy reasons and restrict foreign trade towards certain countries. The embargoes can be total, partial or arms embargoes and can affect exports, imports, capital movement and payments, service provisions, and contract conclusions

BAFA announces new general license in accordance with France-Germany agreement

In October 2019 the Federal Republic of Germany and the French Republic agreed on defense export controls, following the German-French Treaty of Aachen from January 2019. In consideration of this agreement, Germany’s “Bundesamt für Wirtschaft und Ausfuhrkontrolle” (BAFA) has created the new General License No. 28. The new general license was published in the Federal Gazette on 31st March 2020 and comes into force on 1st April 2020. For further details please see the announcem

U.S. issues new executive order regarding bulk-power

On 1st May 2020, U.S. President Trump signed an Executive Order entitled “Securing the United States Bulk-Power System” (E.O. 13920). This Executive Order states that there is a “national emergency with respect to the threat to the United States bulk-power system” and that “foreign adversaries are increasingly creating and exploiting vulnerabilities in the United States bulk-power system.” Therefore, E.O. 13920 prohibits “acquisition, importation, transfer, or installation” o