Key Trade Compliance Topics

US Government imposes new sanctions on Russia

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In the past several days, the US Government has issued a slew of sanctions measures targeting Russia. According to a White House Fact Sheet (see https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/15/fact-sheet-imposing-costs-for-harmful-foreign-activities-by-the-russian-government/), these measures are stated to be in response to Russia’s “harmful foreign activities,” including efforts to undermine free and fair democratic elections and institutions, malicious cyber activities (including the recent SolarWinds incident), transnational corruption, targeting of dissidents and journalists, undermining national security and violating the territorial integrity of states. The latest measures include: 1. A new Executive Order 14024 (see https://www.federalregister.gov/documents/2021/04/19/2021-08098/blocking-property-with-respect-to-specified-harmful-foreign-activities-of-the-government-of-the); 2. The addition of several new parties to the OFAC Specially Designated Nationals and Blocked Persons List (see https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210415), and 3. A related new Directive prohibiting US financial institutions from participating in the primary market for certain ruble, as well as non-ruble, denominated Russian sovereign bonds and loans (see https://home.treasury.gov/system/files/126/sovereign_debt_prohibition_directive_1.pdf).

CBP issues guidance on the suspension of large civil aircraft sec. 301 duties of merchandise from the EU

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On March 12, 2021, CBP issued CSMS #46590066 – GUIDANCE: Suspension of EU Duties in Section 301 Action: Enforcement of U.S. World Trade Organization (WTO) Rights in Large Civil Aircraft Dispute. The purpose of this message is to provide notice of the United States Trade Representative’s (USTR) determination to temporarily suspend additional duties on products of the European Union (EU) under the Section 301 Large Civil Aircraft (LCA) Dispute.  The suspension is effective for products of the EU entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time on March 11, 2021 and before 12:01 a.m. eastern standard time on July 11, 2021.

See https://content.govdelivery.com/bulletins/gd/USDHSCBP-2c6e872?wgt_ref=USDHSCBP_WIDGET_2

President Biden Signs Executive Order to Review and Strengthen US Supply Chains

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On February 24, 2021, President Biden signed an Executive Order on America’s Supply Chains (the “Supply Chain EO”) ordering federal agencies to identify vulnerabilities in key US supply chains and develop policy recommendations to make those supply chains more resilient, diverse, and secure.

See https://www.federalregister.gov/documents/2021/03/01/2021-04280/americas-supply-chains

Biden Administration removes Ansarallah from the SDN List and revokes its designation as a Foreign Terrorist Organization

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On February 16, 2021, the US Treasury Department’s Office of Foreign Assets Control (OFAC) removed Ansarallah, a political movement and militia group in Yemen also known as the Houthis, from the Specially Designated Nationals and Blocked Persons List (“SDN List”). Ansarallah had been added to the SDN List on January 19, 2021, as a Foreign Terrorist Organization (“FTO”) and Specially Designated Global Terrorist (“SDGT”). As a result of the removal, US Persons no longer require authorization from OFAC to engage in transactions or activities with Ansarallah, which broadly controls the northern part of Yemen, provided such activities do not involve blocked persons or otherwise prohibited activities.

See  https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210216

US Government Imposes Sanctions Against Burma

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On February 10, 2021, President Biden issued Executive Order 14014 “Blocking Property with Respect to the Situation in Burma” (EO 14014), which provides for the imposition of sanctions on certain Burmese parties in response to the Burmese military’s coup against the democratically elected civilian government in Burma. In parallel with the issuance of EO 14014, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated thirteen parties on February 10, 2021 and two parties on February 22, 2021 connected to the military apparatus responsible for the coup.

See:

https://www.govinfo.gov/content/pkg/FR-2021-02-12/pdf/2021-03139.pdf

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210211

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210222_33