Worldwide: Checklists Of Foreign Countries Subject To Sanctions

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Thompson Coburn LLP's International Commerce attorneys counsel clients in the legal aspects of shipping goods, services and technologies across international borders. We regularly advise clients on customs compliance and export controls, foreign investment, international finance, immigration and the protection of intellectual property rights.  Our attorneys regularly represent clients before the related agencies under the U.S. Department of Homeland Security, the U.S. Department of Commerce, the U.S. Department of the Treasury and the U.S. Department of State, as well as the U.S. International Trade Commission, the Office of the U.S. Trade Representative, the U.S. Congress and international bodies.

Since the firm's founding in 1929, we have represented clients from nearly every industrial and corporate sector, including energy, banking, transportation, manufacturing and communications. Now, with more than 380 attorneys and 50 practice areas, we continue to serve clients throughout the United States and abroad.

Countries Subject to Various Restrictions by the U.S., EU, and UN

The following are checklists of countries that are subject to a variety of U.S. and EU-imposed restrictions affecting international trade. The countries are grouped into different categories based upon their nature; several of the countries are subject to more than one category of restriction. Although there is considerable overlap between the U.S. and EU checklists, the restrictions applicable to a particular country may differ significantly. Explanatory notes following the two checklists describe the different categories of restrictions for each.

The last page describes sanctions mandated by UN Security Council resolutions and also sets forth information regarding sanctions implemented by certain other countries.

Please note: The attached checklists are intended to alert users to possible issues involving transactions with the named countries or designated persons. They are not intended to constitute, or substitute for, legal advice. Because sanctions programs are subject to change, it is important to review, in advance, any planned dealings with sanctioned countries or persons.

Recent Sanction News

February 26, 2018

The European Union (EU) increased its sanctions on the North Korean regime to align with UN Security Council Resolution 2397 (2017), including caps on refined petroleum products, bans on additional major categories of imports from and exports to North Korea, and additional maritime restrictive measures.

February 23, 2018

U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) announced additional sanctions measures against North Korea targeting shipping and trade entities and released a trade bulletin identifying sanctions circumvention strategies employed by North Korea.

January 26, 2018

The U.S. Government made redesignations and identifications of Russian individuals required by the Countering America's Adversaries Through Sanctions Act (CAATSA). The Trump administration declined to further restrict Russian defense and intelligence entities already identified.

January 22, 2018

The EU added Venezuelan Government officials to its Venezuela sanctions list with Council Decision (CFSP) 2018/90, Council Implementing Regulation (EU) 2018/88.

December 21, 2017

The EU adopted Council Decision (CFSP) 2017/2426, to extend sanctions targeting Russian financial, energy and defense sectors until July 31, 2018.

December 21, 2017

OFAC added five individuals to the Magnitsky Act list, bringing the total number of individuals blocked under the program to 49 individuals. The Magnitsky Act targets individuals connected to the detainment, torture, and death of a Russian lawyer- turned-whistleblower who exposed state fraud and corruption.

November 13, 2017

The EU adopted an arms embargo and the structure to implement asset freeze and travel-related sanctions on targeted individuals in the Venezuelan Government per Council Regulation (EU) 2017/2063 and Council Decision (CFSP) 2017/2074.

November 8, 2017

OFAC amended the Cuban Assets Control Regulations, 31 C.F.R. part 515 (CACR), to implement President Trump's June 2017 National Security Presidential Memorandum regarding policy toward Cuba. The regulatory changes are intended to divert economic activities away from Cuban military, intelligence, and security services, but explicitly maintain opportunities for Americans to travel to Cuba and support private small business there.

October 31, 2017

In accordance with Section 223(d) of CAATSA, OFAC amended Directive 4 of its Sectoral Sanctions program. Directive 4 now prohibits the provision of goods, technology, and non-financial services to deepwater, Arctic offshore, or shale projects in any location where a listed entity has a 33% or greater ownership interest. The delayed effective date of this modification was January 29, 2018, and OFAC published new and updated FAQs relating to the amendment. Additionally, OFAC published new FAQs related to CAATSA Sections 223(a), 226, 228, and 233.

October 24, 2017

OFAC issued Belarus General License 2D, extending the authorization to conduct business with certain state-controlled designated entities, in conjunction with the U.S. Department of State. The License expires April 30, 2018, unless extended.

October 16, 2017

The EU restated its commitment to the implementation of the JCPOA following President Trump's decision to not certify Iran's continuing compliance with the JCPOA.

October 12, 2017

The U.S. revoked certain Sudan and Government of Sudan sanctions, pursuant to Executive Order (EO) 13761, as amended by EO 13804. OFAC published new Frequently Asked Questions regarding this revocation, as well as a new general

license authorizing certain transactions pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000. This action does not affect OFAC sanctions related to the conflict in Darfur, which were imposed pursuant to EO 13400 pursuant to the national emergency declared in E.O. 13067.

September 29, 2017

The EU acted (Council Decision (CFSP) 2017/1775) to implement UN Resolution 2374 permitting sanctions with respect to those threatening Mali's peace agreement.

September 29, 2017

OFAC amended Sectoral Sanction Directives 1 and 2 pursuant to Title II of CAATSA, with a delayed effective date of November 28, 2017. Among other changes, the amendments shortened the maturity window of Directive 1 debt to 14 days and Directive 2 debt to 60 days. OFAC also published updated FAQs relating to the amended Directives.

September 21, 2017

President Trump issued a new EO on September 20, 2017 (EO 13810) imposing additional sanctions on North Korea following an escalation in regional tensions. The measures target banks and other financial institutions that enable the country's WMD capabilities. OFAC concurrently released new and updated FAQs along with new General License 10 and revised General License 3-A.

August 24, 2017

President Trump  issued EO 13808 extending the measures against Venezuela  to prohibit transactions, financing for, and dealings in debt (greater than 30 days

maturity), bonds, and dividend payments of the Government of Venezuela, and debt of Petroleos de Venezuela, S.A. (PdVSA) (greater than 90 days maturity), among other restrictions aimed at diminishing the Venezuelan Government's access to U.S. currency. The action follows increasing instability in the country and the ongoing actions of the controversial Constituent Assembly to revise core democratic aspects of the Venezuelan Government. OFAC previously designated high-ranking members of the Venezuelan Government in August and July 2017.

August 2, 2017

CAATSA became law (PL No. 115-44). The law codified some existing sanctions on sectors of the Russian economy and defense industries, and imposed additional economic sanctions on Russia, Iran, and North Korea. While Russia is not subject to comprehensive sanctions, CAATSA demonstrated strong congressional intent to punish Russia for election interference and keep many economic measures in place that affect the Russian energy, financial, and defense industries for the foreseeable future.

June 16, 2017

President Trump signaled a strong disinclination to continue President Obama's rapprochement with Cuba, announcing upcoming changes to the Cuba sanctions program that will more closely restrict authorized individual travel to Cuba and permissible dealings with the Cuban government and military, intelligence, or security services.

June 8, 2017

The EU adopted Council Decision 2017/975 implementing UN Security Resolution 2356 (2017), imposing asset freezes and travel bans on 18 North Korean officials.

June 2, 2017

The UN Security Council adopted Resolution 2356 (2017), imposing new sanctions on 18 North Korean officials in response to North Korea's ballistic missile tests.

June 1, 2017

OFAC announced additional North Korean designations, including designations of certain Russian oil and gas companies for their conduct regarding North Korea.

The designations are notable because the Russian companies, are not located in or owned by North Korea; rather, the companies are Russian and were identified as supplying North Korea with petroleum and circumventing sanctions.

May 29, 2017

The EU adopted Council Decision 2017/917, renewing sanctions on Syria, including asset freezes and travel bans, until June 1, 2018.

May 17, 2017

OFAC announced designations of several Chinese companies pursuant to "secondary sanctions" stemming from OFAC's Non-Proliferation Weapons of Mass Destruction sanctions program. Secondary sanctions target non-U.S. persons for conduct occurring outside of U.S. territory, making U.S. persons unable to do business with the target. Secondary sanctions are becoming a more common part of OFAC's   actions against North Korea.

April 25, 2017

The EU adopted Council Decision 2017/734, renewing sanctions on Burma/Myanmar until April 30, 2018.

April 24, 2017

OFAC designated dozens of employees of the Syrian Scientific Studies and Research Center, an entity believed to be related to the country's capacity for production and use of chemical weapons. The designation is notable because regular employees, not just company leadership, are included in the designation.

April 20, 2017

OFAC published Frequently Asked Questions related to petitions for removal from the SDN list.

April 11, 2017

The EU adopted Council Decision 2017/689, renewing human rights-related sanctions on Iran until April 13, 2018.

April 7, 2017

The EU adopted Council Decision 2017/666, expanding existing sanctions on North Korea to include restrictions on conventional arms, metallurgy, and aerospace.

The sanctions also prohibit providing services relating to computers, mining, and chemical production, among other services to North Korea.

April 1, 2017

Part 8 of the Policing and Crime Act of 2017 was implemented, allowing UK's HM Treasury to assess civil penalties for financial sanctions violations. The maximum penalty was established at the greater of £1 million or 50 percent of the estimated value of the funds or economic resources. The Act also increases the maximum penalty from two to seven years, among other changes.

March 31, 2017

The EU adopted Council Decision 2017/621, extending restrictive measures with regard to Libya for an additional six months.

March 31, 2017

OFAC announced additional designations of North Korean individuals and entities, including Paeksol Trading Corporation and North Korean individuals located in Russia.

March 30, 2017

The EU adopted Council Decision 2017/607, extending restrictive measures with regard to Bosnia and Herzegovina until March 31, 2018.

March 14, 2017

U.S. Department of Commerce, Bureau of Industry and Security (BIS) announced a

$27 million fine of a Florida-based mail and package forwarding company for alleged violations of the EAR stemming from evasion and illegal attempts to export rifle scopes, night vision devices, and other weapons parts and EAR99 items.

March 13, 2017

The EU adopted Council Decision 2017/445, extending Ukraine-related asset freezes and travel bans until September 15, 2017.

March 7, 2017

OFAC announced a $100 million settlement agreement with Zhongxing Telecommunications Equipment Corporation and its subsidiaries and affiliates (ZTE) for apparent violations of the Iranian Transactions and Sanctions Regulations, 31

C.F.R. Part 560 (ITSR). ZTE allegedly used third-party companies to covertly supply Iran with large quantities of U.S.-origin goods, including controlled goods appearing on the Commerce Control List (CCL). Separately, BIS announced a $1.19 billion penalty against the company for illegally shipping telecommunications equipment to Iran and North Korea in violation of the Export Administration Regulations (EAR) and the ITSR. It is the largest civil penalty ever imposed by BIS.

March 3, 2017

The EU adopted Council Decision 2017/381, extending certain restrictive measures with respect to Ukraine until March 6, 2018.

February 27, 2017

The EU adopted Council Decision 2017/350, extending restrictive measures against Belarus until February 28, 2018.

February 27, 2017

The EU adopted Council Decision 2017/345, implementing UNSC Resolution 2321 (2016), providing for new measures against the Democratic People's Republic of Korea. These include export bans for copper, nickel, silver, zinc, statues, helicopters, and vessels; the tightening of prohibitions in the transport sector; and new restrictions in the banking sector.

February 17, 2017

The EU adopted Council Decision 2017/288, extending restrictive measures against Zimbabwe until February 20, 2018, and amending Council Decision 2011/101 to permit the export of certain equipment that might be used for internal repression where the equipment is solely for civilian use in mining or infrastructure projects, subject to authorization on a case-by-case basis.

February 9, 2017

The Department of the Treasury implemented the Federal Civil Penalties Inflation Adjustment Act with the issuance of new regulations. The adjustments increase penalty amounts and figures in the base penalty matrix by anywhere from 10-100% (or more) in various Treasury sanctions programs.

February 2, 2017

OFAC updated its list of medical devices requiring specific authorization under the Iranian Transactions and Sanctions Regulations.

February 2, 2017

OFAC released General License No. 1, authorizing certain transactions with Russia's Federal Security Service (FSB). Subject to particular limits, transactions authorized include "[r]equesting, receiving, utilizing, paying for, or dealing in licenses, permits, certifications" from the FSB for importing, distributing, or using information technology products in Russia.

January 13, 2017

OFAC  published a final rule amending Sudanese sanctions by broadly authorizing  (via a General License Authorizing Transactions Involving Sudan, 31 C.F.R. § 538.540) transactions with individuals and entities in Sudan and unblocking property involving the Government of Sudan. Sanctions against North Sudan remain technically in force until July 12, 2017, when Executive Orders 13067 and 13412 are scheduled to be revoked.

December 20, 2016

The U.S. updated its Specially Designated Nationals (SDN) List and the Sectoral Sanctions Identifications (SSI) List to target additional Russian/Ukrainian entities due to the ongoing conflict in Ukraine and published a Russia/Ukraine-related General License 11, related to project design reviews or permits from FAU Glavgosekspertiza Rossii's office(s) in the Russian Federation.

October 14, 2016

The U.S. announced additional Cuban Assets Control Regulations (CACR) revisions, easing Cuban sanctions related to scientific collaboration, humanitarian activities, trade, and commerce. The primary embargo on Cuba remains in place.

October 7, 2016

The U.S. terminated the national emergency in Burma by Executive Order, revoking prior Burma-related Executive Orders, and removed specially designated and blocked persons from its financial sanctions list for that country. Other persons in Myanmar remain restricted due to other sanctions programs (e.g., narcotics trafficking, etc.).

Myanmar is still subject to enhanced export controls under the Export Administration Regulations (EAR) and anti-money-laundering special measures.

September 20, 2016

The EU adopted Council Decision 2016/1693, imposing restrictive measures against members of Al Qaida and ISIL, including an arms embargo, asset freezes, and travel restrictions.

September 14, 2016

Executive Order 13739 terminated the national emergency in the Côte d'Ivoire, and the U.S. removed specially designated and blocked persons from its program list for that country.

September 1, 2016

The U.S. updated its SDN List and the SSI List to target additional Russian/Ukrainian entities, including a major Russian construction firm and financial organizations, pursuant to the continuing sanctions program under E.O. 13661.

August 4, 2016

The EU adopted Council Decision 2016/1341, expanding restrictions on North Korea, including placing restrictions on vessels flagged by North Korea and expanding the list of restricted items.

June 20, 2016

The EU adopted Council Decision 2016/994, terminating the arms embargo on Liberia.

June 9, 2016

The EU adopted Council Decision 2016/917, terminating restrictive measures on Côte d'Ivoire.

May 27, 2016

EU adopted Council Decision 2016/849, broadly expanding North Korean sanctions to include prohibitions on the export of dual-use goods and technology, imports

of petroleum products and luxury goods from North Korea, funds transfers to and from North Korea, and investments between North Korea and Europe, among other restrictions.

May 25, 2016

UNSC adopted resolution 2288 (2016), terminating sanctions on Liberia, including arms restrictions.

April 29, 2016

The U.S. extended a Belarus-related general license for transactions with certain specially designated Belarussian state entities.

April 29, 2016

The EU adopted Council Decision 2016/627, extending the arms embargo and human rights-related sanctions on Myanmar until April 30, 2017.

April 28, 2016

UNSC adopted resolution 2283 (2016), terminating all arms, travel, and financial sanctions against Côte d'Ivoire.

March 31, 2016

The EU adopted Council Decision 2016/476, implementing UN restrictive measures against North Korea, including sectoral restrictions on importations of gold, titanium ore, iron, and other metals/minerals; restrictions on the sale or supply of aviation fuel; restrictions on correspondent banking relationships with entities linked to North Korea; and requiring inspection of North Korean vessels and vessels going to or from North Korea, among other restrictions.

March 16, 2016

The U.S. issued Executive Order 13722, announcing the blocking of the Government of North Korea and Workers' Party property and the prohibition of certain other transactions. In conjunction, the U.S. Treasury announced that the transportation, mining, energy, and financial services industries in the North Korean economy would be targeted.

March 15, 2016

The U.S. published updated CACR to further relax economic sanctions in effect for Cuba. Certain sanctions related to travel, trade, financial services, commerce, humanitarian issues, and banking were relaxed.

January 16, 2016

The P5+1, the European Union, and Iran reached Implementation Day, resulting in the lifting of certain sanctions against Iran. The U.S. lifted nuclear-related sanctions on Iran, and provided guidance on various licenses and exceptions. But broad U.S. sanctions remain in effect for U.S. and U.S.-controlled entities. Meanwhile the EU lifted almost all remaining sanctions on Iran. However, EU restrictions remain on exports of certain goods and technology, including goods/technology listed on the Nuclear Suppliers Group list, software designed for use in nuclear and military industries, and graphite and certain raw or semi-finished materials.

Download >> Checklists Of Foreign Countries Subject To Sanctions

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