The Month in International Trade – June 2024

Client Alert | 6 min read | 07.10.24

Top Trade Developments

EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG, and the Transportation Sector
OFAC Sanctions Shadow Banking Network for Iran Military
Growing Technology Supply Chain Risks: Kaspersky Lab Software Banned in First Use of ICTS Supply Chain Prohibition
Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain, and IT Support for Russia Operations
Navigating Compliance: Preparing for the EU Corporate Sustainability Due Diligence Directive
Global Trade Talks: Force Labor – Mitigating Risk in Auto Industry and Other Sectors

This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.

Top Trade Developments

EU Implements Long-Awaited “14th Round” of Sanctions Against Russia, Further Targeting Circumvention, LNG, and the Transportation Sector

An overview on new Russian sanctions and export controls issued by the European Union, focusing on anti-circumvention measures and the Russian financial, military, and LNG industries.

Click here to continue reading the full version of this alert.

For more information, contact: Dj Wolff, Vassilis Akritidis, Nicola Phillips, Jeremy Iloulian, Sophie Davis, Perfilippo Natta

OFAC Sanctions Shadow Banking Network for Iran Military

On June 25, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 50 entities and individuals comprising an expansive “shadow banking” network used by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) to gain access to the international financial system, and added these individuals and entities to OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), noting they constituted Specially Designated Global Terrorists (SDGT). The network, comprised of Iranian exchange houses and dozens of foreign cover companies under their control, enabled MODAFL and the IRGC to generate revenue used to procure and develop advanced weapons systems, provide weapons and funding to regional proxy groups, and transfer UAVs to Russia for use in its war against Ukraine. As part of the nearly 50 newly sanctioned persons are 27 “cover companies” located in Hong Kong, the United Arab Emirates, and the Marshall Islands.

Now, unless an OFAC license is granted, all U.S. persons are prohibited from dealing with these entities and individuals, and any entity they own 50% or more, and all persons (U.S. or otherwise) are prohibited from exporting, reexporting, or transferring (to these sanctioned persons) any item subject to U.S. Export Administration Regulations.

OFAC’s action underscores its continued focus on finding and sanctioning parties involved with aiding Iran and is the second such instance of OFAC taking action against groups of entities operating as a shadow banking network for Iran. In March 2023, OFAC sanctioned several dozen entities that moved the proceeds of petrochemical sales for the regime to support Hamas, Hizbollah, and the Houthis.

For more information, contact: Anand Sithian, Jeremy Iloulian, Edward Goetz

Growing Technology Supply Chain Risks: Kaspersky Lab Software Banned in First Use of ICTS Supply Chain Prohibition

On June 20, 2024, the U.S. Department of Commerce Bureau of Industry and Security announced its first Final Determination pursuant to the Securing the Information and Communications Technology and Services Supply Chain (ICTS) regulations, prohibiting Kaspersky Lab, Inc. from providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons, setting the stage for future risks to software supply chains involving Russia or China.

Click here to continue reading the full version of this alert.

For more information, contact: Addie Cliffe, Caroline Brown, Jana del-Cerro, Jeremy Iloulian, Edward Goetz

Pressure Rising: New U.S. and UK Sanctions and Export Controls Increase Risks for Lingering Russia Exposure, Indirect Evasion in the Supply Chain

An overview on new Russian sanctions and export controls issued by the U.S. (OFAC and BIS) and the UK focusing on the Russian financial, military, and LNG industries.

Click here to continue reading the full version of this alert.

For more information, contact: Caroline Brown, Carlton Greene, Dj Wolff, Jeremy Iloulian, Sophie Davis, Kelsey Clinton

Navigating Compliance: Preparing for the EU Corporate Sustainability Due Diligence Directive

The Corporate Sustainability Due Diligence Directive represents a significant step in aligning corporate activities within sustainable and ethical practices, reinforcing the EU’s commitment to environmental and human rights standards.

Click here to continue reading the full version of this alert.

For more information, contact: Vassilis Akritidis, David Stepp, Perfilippo Natta, Jean-Baptiste Blancardi, Sophie Davis

Global Trade Talks: Forced Labor – Mitigating Risk in Auto Industry and Other Sectors

Global Trade Talks is a podcast that shares brief perspectives on key global issues on international trade, current events, business, law, and public policy as they impact our lives. In this session, hosts and International Trade Practice Leaders Nicole Simonian and Dj Wolff talk with Crowell lawyers David Stepp and Simeon Yerokun about Uyghur Forced Labor law and its recent application to the auto industry.

Listen: Crowell.com | PodBean | SoundCloud | Apple Podcasts

For more information, contact: Nicole Simonian, Dj Wolff, David Stepp, Simeon Yerokun

Crowell Speaks

40 Under 40 2024: Anand Sithian
June 27, 2024 – Global Investigation Review
Related Professionals: Anand Sithian

The Future According to the 40 Under 40: Part I
June 27, 2024 – Global Investigation Review
Related Professionals: Anand Sithian

Banking Cryptocurrency Companies After Crypto Winter – (June 13, 2024).
Speaker: Anand Sithian

Doing Business with the U.S. Government – West Coast Government Contracts Seminar (June 11 and 12, 2024).
Speakers: Jana del-Cerro and Addie Cliffe

Special Focus on China: New, Unique Considerations Affecting Your Compliance Strategy – FCPA Enforcement and Compliance (June 12, 2024).
Speaker: Evan Chuck

Scripps News Live – Biden’s China EV Tariffs (Video Download)
June 6, 2024 – Scripps News
Related Professionals: Evan Chuck