|After the UK Brexit referendum of 23 June the implications on the political, economic and legal relations between the UK and the EU have been discussed from many angles. But what about...|
Iran: New Developments and Additional Sanctions
The United States and European Union have continued to impose or propose additional sanctions and restrictive measures targeting certain dealings with Iran or with designated persons and entities. These developments include: (1) a recent decision by the Council of the European Union (EU) to require financial messaging providers to discontinue communication services to certain Iranian financial institutions, which effectively cuts off those Iranian banks from accessing international funds transfers, (2) the new EU Council Regulation, which implements various Iran sanctions measures from 2012 and makes substantive changes to existing provisions, (3) a recent temporary exemption by the U.S. State Department of eleven countries from the Iran sanctions under the National Defense Authorization Act of 2012 (NDAA), which will enable financial institutions from those countries to process certain Iran-related transactions (during a 6-month period) without exposing themselves to possible restrictive measures under the NDAA, (4) the issuance of the revised Iranian Financial Sanctions Regulations implementing the provisions of the NDAA targeting certain dealings by non-U.S. financial institutions with the Central Bank of Iran (CBI) and designated Iranian financial institutions, and (5) several bills pending in the U.S. Congress that would further expand sanctions against Iran. For additional information related to these recent developments, please see the Hogan Lovells Economic Sanctions Alert on Iran Sanctions Developments, dated 29 March 2012.
The Department of Energy (DOE) recently published its revised Part 810 Guidance on compliance with the amended Part 810 Regulations on nuclear export controls (10 C.F.R. Part 810). The 2015 ...24 June 2016
FinCEN Designates North Korea as a Jurisdiction of Primary Money Laundering Concern, Triggering Additional Due Diligence Requirements for Financial Institutions
Pursuant to the North Korea Sanctions and Policy Enhancement Act of 2016’s requirement that the Secretary of the Treasury determine whether North Korea is a jurisdiction of...16 June 2016