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The good, the bad and the ugly: implementation of the Iran sanctions legislation begins

USA, Iran - October 15 2012 On October 9, 2012, President Obama signed Executive Order 13628 “Authorizing the Implementation of Certain Sanctions Set Forth in the Iran Threat Reduction and Syria Human Rights Act of 2012 and Additional Sanctions with Respect to Iran” (the Order)....

Kay C. Georgi.


Burmese sanctions law update at long last, sanctions eased

USA, Myanmar - July 13 2012 As eagerly anticipated, the US Government has finally relaxed the sanctions against Burma....

Kay C. Georgi, Jeffrey R. Lord.


Obama Administration targets Syrian and Iranian users of information and telecommunications technology capable of communications disruption and monitoring, and their suppliers

USA, Syria, Iran - April 30 2012 On April 22, 2012, the President signed a new Executive Order Blocking the Property and Suspending Entry into the United States of Certain Persons with Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via Information Technology (Executive Order 13606, dubbed the “GHRAVITY EO”)....

Kay C. Georgi, Valentin A. Povarchuk.


BIS publishes final regulation creating 0Y521 ECCNs for emerging technologies, making it easier for BIS to control first, ponder later

USA - April 24 2012 On April 13, 2012, the US Commerce Department's Bureau of Industry and Security (BIS) published a final regulation establishing the 0Y521 ECCN series with a view towards providing a mechanism for identifying and controlling potentially sensitive emerging technologies not yet categorized on the US Commerce Control List or the US Munitions List....

Kay C. Georgi, Regan K. Alberda.


DDTC’s proposed ITAR brokering regulations in (relatively) plain English

USA - January 4 2012 As most of you are well aware, on December 19, 2011, the US Department of State, Directorate of Defense Trade Controls (DDTC) published the long-awaited proposed rule on defense brokering....

Kay C. Georgi, Regan K. Alberda.