As the United Kingdom moves closer to its withdrawal date from the European Union in October, traditional “cookie cutter” compliance programs will not be sufficient for companies looking to remain compliant with global sanctions in Brexit’s aftermath, said Tina Carlile, a senior counsel for international trade at BP.
Correction: This memorandum was issued April 19, 2018.
Venezuelan President Nicolas Maduro is evading U.S.-imposed sanctions by funneling cash from Venezuelan oil sales through a Russian state energy company, according to an April 18 report from Reuters. The cash flowing through Rosneft is the most recent sign of “the growing dependence of Venezuela’s cash-strapped government on Russia” as a result of U.S. sanctions, according to the report.
Even with an already high volume of U.S.-imposed sanctions on Venezuela’s oil and economic sectors within the first few months of 2019, the sanctions are only likely to increase, said Johann Strauss, an international trade lawyer at Akin Gump.
Officials from the State and Commerce departments underscored the importance of open communication and urged industry leaders to submit public comments as the two begin a review of space-related export controls under a Trump administration directive. At the April 17 public meeting at the Department of Commerce, several officials, including Commerce Secretary Wilbur Ross, said they were seeking public comments on an advanced notice of proposed rulemaking for both State and Commerce, specifically surrounding items listed on the U.S. Munitions List regarding categories IV and XV: launch vehicles and spacecraft, respectively. The notices were issued March 8; comments are due April 22.
New Zealand implemented a range of gun control regulations on April 12, banning most semi-automatic firearms and introducing penalties for importing guns without a permit, according to an April 17 notice from Baker McKenzie and the New Zealand Parliamentary Counsel Office. The regulations also contain provisions that can penalize exporters or importers who “knowingly [supply] or [sell] a prohibited firearm or prohibited magazine to a person who does not hold a permit to import or possess one,” according to Baker McKenzie.
Companies and individuals who violate New Zealand customs requirements can now be issued a range of instant fines, according to a list of infringement offenses from New Zealand Customs. The list was mentioned in an April 17 notice from Baker McKenzie. The changes were introduced in October as part of the country’s Customs and Excise Act of 2018 but were not implemented until after a six-month “education phase,” according to the notice. They became effective April 1, 2019.
The State Department is seeking Office of Management and Budget approval of the information it will collect through an “online case management system” that will consolidate several Directorate of Defense Trade Controls licensing forms, it said in a notice. The new DS-7788 will be used to review and adjudicate requests to export or temporarily import defense articles, defense services and related technical data. After the new system is implemented, DDTC will discontinue the use of several forms consolidated into the new DS-7788: the DSP-5, DSP-6, DSP-85, DSP-73, DSP-61, DSP-62, DSP-74, DS-6004 and DS-4294. Comments are due to State by June 18.
SAN ANTONIO -- The Commerce Department's Bureau of Industry and Security and the Census Bureau hope to issue their long-awaited proposed regulations on routed export transactions in late spring or early summer, said Sharron Cook, senior policy export analyst at BIS, at the National Customs Brokers & Forwarders Association of America's annual conference April 17. When they come out, Cook thinks, export forwarders will see two of their bigger headaches with the current regulations on track for resolution.
The State Department is amending the International Traffic in Arms Regulations to make changes to its licensing exemption for transfers made by or for an agency of the U.S. government. The scope of the revised exemption is now expanded to allow for permanent exports and retransfers, as well as transfers by third parties acting for the U.S. government. The final rule takes effect April 19.