Iran said it may take a “third step” to further breach the Joint Comprehensive Plan of Action if the agreement’s parties do not do more to mitigate the U.S.’s 2018 withdrawal from the JCPOA, the country’s Ministry of Foreign Affairs said in an Aug. 1 press conference. Iran also called on the agreement's parties to help mitigate the impacts of U.S. sanctions. “Sanctions make fulfilling some of our promises harder … [but] one of the opportunities that sanctions provide us is increased empathy and cooperation among us,” Iran said. Iran last month surpassed the enriched uranium limit that was agreed to as part of the JCPOA, sparking concern from the European Union and additional threats of sanctions by the U.S. (see 1907080019).
The Treasury’s Office of Foreign Assets Control on Aug. 3 issued a “Russia-related directive” and a set of frequently asked questions to pair with President Donald Trump’s Aug. 1 executive order on chemical and biological weapons sanctions.
President Donald Trump’s Aug. 1 executive order (see 1908020020) announcing a second round of sanctions on Russia under The Chemical and Biological Weapons Control and Warfare Elimination Act includes export licensing restrictions for certain Commerce-controlled goods and technologies, the State Department said. In a fact sheet issued Aug. 2, the agency said all license applications for exporting chemical or biological weapon-related items to Russian state-owned entities are subject to a policy of presumption of denial. License exceptions, however, will "continue to be available" to U.S. companies involved in existing contracts with Russian customers, the State Department said.
CBP updated its mitigation guidelines for export control seizures to include new mitigating factors, aggravating factors, a new list of remission terms and the elimination of the terms “technical violations” and “substantive violations,” CBP said in its updated July guidelines. In previous years, CBP distinguished between technical and substantive violations but said in its most recent guidelines that the terms were “confusing and misleading” to both CBP officers and the public because they were not used by other licensing agencies.
The U.S. publicly sanctioned two Venezuelan military officials for “gross violations of human rights,” the State Department said Aug. 2. The agency said the U.S. sanctioned Rafael Enrique Bastardo Mendoza, commander of Venezuela’s police special forces, and Ivan Rafael Hernandez Dala, commander of military counter intelligence, for acts that were “documented extensively in the July 5, 2019 report by the United Nations High Commissioner for Human Rights ... [that] noted at least 7,523 extrajudicial killings documented by a Venezuelan non-governmental organization.” Secretary of State Mike Pompeo said in a statement that “in addition to the designation of Bastardo and Hernandez, I am publicly designating Bastardo’s spouse, Jeisy Catherine Leal Andarcia, and Hernandez’s spouse, Luzbel Carolina Colmenares Morales, as well as the minor children of both officials.”
President Donald Trump issued an executive order on Aug. 1 to give the State and Treasury departments the ability to impose more sanctions on countries using chemical or biological weapons. The new sanctions include restrictions on financial loans by international banks, blocking measures and trade controls.
The European Union council removed two people from its Libya sanctions list, the EU said Aug. 2. The EU delisted Abdussalam Mohammed Abdussalam and Abdulqader Mohammed al-Baghdadi.
U.S. sanctions on Iran (see 1907080019) will not lead to a clear outcome, said Sarah Ladislaw, director of the Center for Strategic and International Studies Energy and National Security Program, adding that the U.S.’s failure may leave it without a contingency plan.
Japan officially approved removing South Korea from its so-called whitelist of trusted trading partners, the Japanese Ministry of Economy, Trade and Industry said Aug. 2, adding that it will begin enforcing the decision Aug. 28. The move was expected after Japan introduced a bill earlier this month as the two countries become embroiled in a trade dispute (see 1907300058).
As the U.S. continues to impose broad sanctions, companies are increasingly turning away from deals, fearing compliance risks, sanctions lawyers and experts said. While the Trump administration has tried to mitigate sanctions impacts on industry through advance notices, guidance and wind-down periods, the experts said, some of the damages have been unavoidable.