Thomas Krueger, former director of strategic trade and nonproliferation on the National Security Council, has joined Akin Gump as a senior policy adviser, according to a LinkedIn post from firm partner Kevin Wolf. Krueger worked for a decade at the State Department, most recently as a senior policy adviser, before joining the NSC, where he served from 2020 to June 2022. Per his new firm, Krueger advises clients on compliance with the International Traffic in Arms Regulations and the Export Administration Regulations, along with transfer policies for emerging technologies.
The U.K. released three general licenses pertaining to its Russian sanctions regime. The first, "Wind Down of Positions Involving Rosbank," allows until July 30 an individual or entity to wind down any transactions to which it is a party involving Rosbank or a subsidiary. Such action includes closing out of any positions, repaying loans, withdrawing deposits and closing accounts. The next license, "Wind down positions involving National Bank of Belarus," allows an individual to give financial services for winding down any "derivatives, repurchase, and reverse purchase transactions" entered into before July 5 with the National Bank of Belarus, Ministry of Finance of Belarus and those individuals listed under the Belarus sanctions regime. The last license, "Transferable securities, money market instruments, loans and credit arrangements," permits a seven-day wind down period for category C loans and transferable securities and money market instruments under the Belarus sanctions regime.
The U.K. on July 4 amended its Russian sanctions guidance page on prohibitions on insurance and reinsurance services for aviation and space goods to an individual or entity connected with Russia or for use in Russia. The Office of Financial Sanctions Implementation said the "provision of insurance and reinsurance services in respect of a satellite where the only nexus with Russia is that it is orbiting over Russia, or broadcasting to Russia (and where the insurance and reinsurance services will not be provided to a person connected with Russia), would likewise not come within the scope of these prohibitions."
The Bureau of Industry and Security posted the presentation materials from panels during its annual update conference last week. The panels included update sessions on export enforcement (see 2207010010, 2207010025 and 2206300069), recently implemented export controls (see 2207010015), the foreign direct product rule (see 2206300005) and the Directorate of Defense Trade Controls’ regulations (see 2206300029).
The U.N. Security Council last week amended one entry on its sanctions list. The UNSC updated the information for Pak Chun Il, who served as the North Korean ambassador to Egypt, to say he "concluded his tour of duty" and left Egypt Nov. 15, 2016.
The U.K. added seven new entries to its Russia sanctions list while imposing new trade restrictions on Belarus in response to the continued invasion of Ukraine.
The Bureau of Industry and Security this month updated its “Don’t Let This Happen To You” guidance, which includes summaries and case examples of past export control investigations. The 65-page document also includes an overview of the BIS Office of Export Enforcement, the agency’s various authorities and a section on BIS enforcement priorities, which specifically names China, Russia, Iran and North Korea.
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The State Department published its spring 2022 regulatory agenda, including a new mention of a final rule that will expand the types of defense items and services that can be sent to Australia, the U.K. and Canada. The rule would specifically amend the International Traffic in Arms Regulations to expand certain trade under existing defense trade treaties between the countries, and would also amend the Canadian exemptions. Other changes will make “clarifying amendments and conforming updates” to Supplement No. 1 to part 126 of the ITAR, specifically to U.S. Munitions List Categories IV(i), manufacturing know-how, and Category XII, night vision entries. The agency hopes to issue the rule this month.
The European Council on June 30 requested the consent of the European Parliament to add the violation of restrictive measures to the list of "EU Crimes" laid out in the Treaty on the Functioning of the EU, the council said. The move is intended to crack down on the circumvention on the EU's many sanctions regimes, most notably Russia restrictions made following the invasion of Ukraine. With EU member states having different definitions of what constitutes a violation of the EU's sanctions regimes, the council said that greater effort is needed to harmonize sanctions enforcement.