Exporters shouldn't expect a grace period from enforcement under the Bureau of Industry and Security's new 50% rule, but the agency likely is first looking for intentional violators as opposed to exporters who made good-faith efforts to comply, industry lawyers and advisers said in interviews.
Sens. John Cornyn, R-Texas, and Jeanne Shaheen, D-N.H., introduced a bill Sept. 30 that would allow the president to use International Emergency Economic Powers Act sanctions against transnational criminal organizations that conduct large-scale cyber scams targeting Americans.
Sens. John Cornyn, R-Texas, and Alex Padilla, D-Calif., introduced a bill Sept. 29 that's designed to protect American companies that are sued in federal court for complying with U.S. sanctions and export controls, especially those against Russia.
Canada imposed new sanctions on Iran Oct. 1 following the U.N.'s move last month to reimpose Iranian restrictions that were paused after the 2015 nuclear deal. The Canadian measures include "broad prohibitions" on exports to and imports from Iran of nuclear, dual-use and ballistic-missile-related material, equipment and technology; prohibitions on technical and financial assistance related to restricted goods; an arms embargo; and service restrictions for Iranian vessels. The announcement follows similar moves to impose snapback sanctions on Iran by the EU, the U.K. and others (see 2510010018 and 2508280033).
The U.S. ambassador to NATO suggested this week that the Trump administration won’t sign off on any new Russia sanctions until all EU and NATO members stop buying Russian energy.
Although the Bureau of Industry and Security in FAQs this week suggested its new 50% rule applies only to ownership and not the control that a parent company may have over an affiliate, that doesn’t mean U.S. exporters should ignore an Entity Listed company’s controlling influence over an unlisted company, said Mike Huneke, a trade lawyer with Morgan Lewis.
The Bureau of Industry and Security on Sept. 30 again renewed the temporary denial order for Russia's Ural Airlines, saying it has continued to illegally operate flights within Russia and to and from Tajikistan and Kyrgyzstan. The order, first issued in October 2022 (see 2210170009) and renewed multiple times, bars the airline from participating in transactions with items subject to the Export Administration Regulations. The order was renewed for one year.
Senate Banking Committee member Mark Warner, D-Va., urged the Bureau of Industry and Security on Sept. 30 to consider placing export controls on open-source technologies that could benefit China.
The U.K. on Oct. 1 reimposed nuclear-related sanctions on Iran covering 121 people and entities, which were paused after the 2015 Iranian nuclear deal. The reimposition of the restrictions follows the reinstatement of the so-called "snapback" sanctions earlier this week at the U.N. (see 2508280033).
The Office of Foreign Assets Control this week sanctioned nearly 40 people and entities with ties to networks helping to buy sensitive goods and technology for Iran’s Ministry of Defense and Armed Forces Logistics, along with its missile and military aircraft production efforts.