Bureau of Industry and Security Imposes Additional Sanctions on Russian Oil Industry and Adds Individual to its Entity List
In early August, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a new rule imposing further sanctions against Russia to implement U.S. policy addressing Russia’s destabilization of Ukraine and continued occupation of Crimea and Sevastopol. The new rule imposes export controls on specified items used in the Russian energy sector intended for oil and gas deepwater, Arctic offshore and shale exploration projects. The rule also designates an additional person deemed to be acting contrary to U.S. national security and foreign policy interests for the BIS Entity List, a list which notifies the public of parties representing a diversion or other risk.
Read the BIS summary and rule.
Extension of the Implementation of the Joint Plan of Action Reached on November 24, 2013 between the P5+1 and Iran
In late July, the United States joined the United Kingdom, Germany, France, Russia and China (collectively, the “P5+1”) in extending temporary sanctions relief to Iran until November 24, 2014, as provided for in the Joint Plan of Action (JPOA) between the P5+1 and Iran. The JPOA, first agreed to in November 2013, embodied commitments from Iran to halt progress on its nuclear program and from the P5+1 to provide limited, targeted sanctions relief to Iran for a six-month period, renewable by mutual consent. The first period of sanctions relief lasted from January 20, 2014 until July 20, 2014. This second period of relief went into effect on July 21, 2014.
JPOA relief applies to certain sanctions involving Iran’s purchase and sale of gold and precious metals, the country’s automotive industry and its export of petrochemical products. It also involved commitments to license transactions related to the safety of Iran’s civil aviation industry, to establish financial channels to facilitate certain humanitarian and educational activities, to pause efforts to further reduce Iran’s crude oil exports, and to provide Iran access to $4.2 billion in blocked funds. The relief extended to Iran does not impact the continued applicability of other U.S. sanctions programs against Iran, which remain in full force, and the United States continues to enforce its prohibition on transactions with Iranian entities on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List).
The United States has the right to revoke its sanctions relief at any time if Iran fails in meeting its JPOA commitments.
OFAC Publishes Iran General License G, Impacting Academic Exchanges and Educational Services
In mid-August, OFAC posted Iran General License G in the Federal Register. OFAC first issued Iran General License G under the Iranian Transactions and Sanctions Regulations (ITSR) in late March 2014, permitting accredited academic institutions in the United States to form undergraduate and graduate academic exchange agreements with universities in Iran, including the provision of scholarships to participating Iranian students. In addition, the license allows U.S. academic institutions and U.S. persons to export to Iran educational services in certain academic disciplines and to administer examinations to Iranian students.
OFAC Amends Sudan General License No. 1A
In April 2013, OFAC issued Sudan General License No. 1A, which authorized certain academic and professional exchange activities with Sudan that were previously prohibited under the Sudanese Sanctions Regulations (SSR). In mid-August 2014, OFAC amended the General License to expand the authorization, permitting specified activities related to the authorized exchanges.
The amendment expands the scope of the definition of “U.S. academic institutions” to include branch campuses abroad. It also permits U.S. academic institutions “to engage in activities involving Sudanese nationals that are necessary for such nationals to apply to U.S. academic institutions” and that would otherwise be prohibited under the SSR, such as accepting tuition payments and application fees. Under the amended license, U.S. financial institutions are permitted to process money transfers from Sudanese nationals for fees and expenses associated with authorized exchange programs or training seminars.