ACFCS QUICK TIPS WEBINAR: SANCTIONS UPDATES IN UNCERTAIN TIMES, UNLOCKED FOR A SHORT TIME

Enjoy this unlocked piece of ACFCS Member Content, one of our Quick Tips webinars. This series provides brief and practical guidance on timely issues. If you are interested in knowing more of what the association has to offer you, please email us at customerservice@acfcs.org. 

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Here is a short description of the event that took place earlier this month: Recent global events have brought tumultuous times for sanctions compliance programs. In May, the US pulled out of a joint deal with Iran to freeze that nation’s nuclear weapons program in exchange for sanctions relief.

Since then, some US politicians have proposed tough new sanctions related to Russia, while others have pushed for relief and selective rollbacks. Meanwhile, an ongoing dialogue between the US and North Korea has raised the possibility of a thaw, but also increased the potential for a sanctions crackdown if talks fail.

This Quick Tips webinar takes a global tour of events impacting sanctions regimes, and provides updates on how they impact your compliance program, including:

  • How the US withdrawal from the Iran nuclear deal is unfolding, what sanctions are returning, and key risk areas to consider
  • New proposed measures for US sanctions against Russia
  • An update on North Korean sanctions concerns, amid uncertainty over de-nuclearization

Here are some snapshots of the presentation:

Iran: US Says No Deal as Sanctions snap back into place

  • U.S. pullout: May –Trump pulls US out of Joint Comprehensive Plan of Action with Iran with E.O. 13846
  • Secondary sanctions: 2015 deal had lifted secondary sanctions related to Iranian banking, petrochemical, energy, aerospace and other industries
  • Evaporating waivers: US Treasury and State revoked sanctions waivers and replaced them with 90 and 180-day temporary waivers

EU Says ‘No Deal’ to the No Dealinvokes blocking statute on August 7th

  • Rarely applied: In place since 1996, seldom used except for Cuba sanctions
  • Broad application: Nationals of EU member states, legal entities incorporated in EU, EU nationals outside of EU, shipping companies owned by EU nationals, residents, nationals of other countries acting in “professional capacity” in EU
  • U.S. nexus: Subsidiaries of US companies formed in EU and with central offices/principal place of business in EU are subject. Branches of US companies in EU are not

North Korea – Dangerous Games

  • June 12 summit – Reduced tensions, few tangible commitments
  • Pulling back? – No tests, dismantling rocket and testing facilities
  • Since then – Multiple reports citing US intel concerns that North Korea is increasing nuclear fuel development, continuing program
  • Can’t commit – Commitment to denuclearization is questionable