International Trade

  • U.S. oilfield services company pays $25 million for violations involving senior managers.
  • Aggressive enforcement continues even though restrictions have been eased.
  • It can take a long time to settle violations of U.S. sanctions and export issues.

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a stark reminder both of existing restrictions and – especially – the U.S. government’s intent to enforce those restrictions aggressively.  (Even if doing so takes a long, long time.)Continue Reading Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

I will be co-hosting a webinar on Tuesday, November 29 on compliance challenges under the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR). Key topics that will be covered in this webinar include ITAR and EAR amendments and new rules; jurisdiction and classification; licensing, agreements, and exceptions; effective compliance practices; recent enforcement;…

Over the past year, the big news for companies doing or considering business in Iran has been the scaling back of U.S. and EU economic sanctions. Many global businesses are now permitted to operate in this once prohibited market. Before we celebrate too enthusiastically, however, let’s stop for a moment to consider a potential challenge for some companies trying to capitalize on this new opportunity.

This time, we are focusing on a conundrum specific to companies that contract with the U.S. government.Continue Reading Iran on Your Mind? The FAR Should Be, Too.

Key points:

  • Leading aircraft manufacturers obtain U.S. government authorization to sell planes to Iran.
  • Issuance of authorizations is notable but may be hard to duplicate in other industries.
  • Even if authorized, companies face practical challenges if pursuing business in Iran.

Boeing and Airbus have overcome another hurdle to tapping into the Iranian market. According to news reports, on September 21, the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) issued licenses to both companies to sell aircraft to Iran.  Boeing’s license is said to authorize the sale of 80 planes; Airbus reportedly has been permitted to export 17 aircraft as part of a larger plan to sell 118 aircraft to Iran.  (Although Airbus is a non-U.S. company, to the extent its aircraft contain more than a de minimis amount of U.S.-origin equipment, Airbus would need a specific authorization from OFAC.)Continue Reading Pioneers of the New Frontier: Boeing and Airbus Cleared to Sell Aircraft to Iran

I offered insights for an article outlining ways that the United Kingdom’s exit from the European Union could affect the Washington, D.C. region. My comments are specific to how the transition could impact government contracting and benefit the defense trade.

The full article, “6 Ways Brexit Could Impact Washington Business,” was published by…

Despite a host of unanswered questions, national security concerns and political barriers, Boeing announced on June 22, 2016 that it has signed a Memorandum of Agreement (MOA) with state-owned Iran Air. If finalized, the agreement would mean that Boeing could sell up to 100 commercial aircraft to Iran, at a cost of roughly $25 billion.

Boeing reportedly obtained a license from the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) to execute the MOA and engage in the negotiations that led to its signing. (OFAC is the U.S. government agency that administers most U.S. economic sanctions on Iran.) That authorization was made possible due to a new licensing policy relating to commercial passenger aircraft that OFAC issued in January 2016, following the July 2015 Joint Comprehensive Plan of Action (JCPOA) between the United States and its allies and Iran. The JCPOA significantly scaled back sanctions against Iran.Continue Reading Iran Update: The Significance of the Boeing Deal

May was a busy month in the world of U.S. defense exports. Perhaps most controversial was President Obama’s decision to terminate the arms embargo against Vietnam. The embargo, in place since 1975, was partially lifted in 2014 to provide Vietnam with greater maritime surveillance and improved security systems. Since then, the United States has contributed $46 million to strengthening Vietnam’s maritime security.

Separately, the U.S. State Department announced that it would begin reviewing applications for licenses to export defense articles and defense services to Cote d’Ivoire, Liberia and Sri Lanka on a case-by-case basis. Those announcements followed three U.N. Security Council Resolutions terminating the U.N. arms embargoes against those nations.Continue Reading The United States Lifts Arms Embargoes Against Vietnam and Other Countries

We recently authored an article outlining the details surrounding the United States’ eased trade restrictions with Cuba. Businesses must carefully analyze the new regulations before venturing into business opportunities in Cuba.

As stated in the article, “in its zeal to ease restrictions, the U.S. government has not always accounted for how to authorise certain activities…

From the Bass, Berry & Sims Blog Network
From the Bass, Berry & Sims Blog Network

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