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On 8th May 2018 President Donald Trump announced the United States’ (U.S.) withdrawal from the Joint Comprehensive Plan of Action (JCPOA) and renewal of U.S. far reaching sanctions. The Agreement, signed in 2015 between Iran, the P5+1 (China, France, Russia, United Kingdom, United States—plus Germany) and the European Union (EU), aimed to curb Iran’s efforts to develop its nuclear program and enrich uranium.
The information security section of the EU dual-use regulations, Category 5 Part 2, has been modified to provide a positive list of controls to improve transparency and clarity around the applicability of these controls. The previous versions of Category 5 Part 2 had applied a broad brush control to encryption items and then sought to decontrol by exception.
U.S. Department of Justice (DOJ) – Enhanced Security Plan Sets Best Practices for Use of Cloud Services for Sensitive Data
In December 2017 a global software company serving the telecommunications industry settled charges with the U.S. Department of Justice for violating U.S. controls on foreign access to sensitive data, including export controlled information. As part of the settlement, the company agreed to implement an Enhanced Security Plan designed to increase information security by regulating remote access to company networks and transfers of sensitive data.
December 2017 brought major updates to India’s trade policy, with the country’s accession to the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies (Wassenaar Arrangement or WA) and the government’s release of a ‘Mid-term Review of Foreign Trade Policy (FTP) in December 2017’ (‘the Review’). These changes have broad implications for exporters operating in India and deserve careful attention across compliance functions, from export controls to tax.
Our Global Export Controls and Sanctions team at Deloitte aligns all of its efforts around providing trusted services to our clients and partners while also making the world a safer place.
The Sanctions and Anti-Money Laundering Bill (the Bill) introduced to the House of Lords on Wednesday 18th October 2017 paves the way for the United Kingdom’s sanctions and anti-money laundering (AML) framework ahead of Brexit. The Bill’s intention is to ensure that when the United Kingdom (UK) leaves the European Union (EU), the UK can continue to impose, lift, amend, and update sanctions and AML regimes: these include financial sanctions, arms embargoes and trade control restrictions, international travel bans, and money laundering regulations.
On November 13, 2017 the European Union imposed a military embargo as well as additional restrictive measures against Venezuela under EU Council Decision No. 2017/2074/CFSP and Council Regulation (EU) No.2017/2063. This sanctions regime came in force on its publication date in the European Union Official Journal (November 14, 2017). The aim of the new sanctions are to prevent the “excessive use of violence or abuse of human rights in Venezuela, in light of the recent deterioration of democracy and the rule of law” following massive protests against the Venezuelan President, Nicolas Maduro.
On 8 August 2017, the UK legislator passed a new Regulation imposing additional recordkeeping and reporting obligations related to financial sanctions compliance by UK professionals. The European Union Financial Sanctions (Amendment of Information Provisions) Regulations 2017 (“the Regulations”) expands the scope of financial sanctions reporting requirements to additional sectors beyond financial institutions, including auditors and external accountants.
On October 12th, 2017 the U.S. revoked part of its financial sanctions against Sudan.
We are excited to inform you that we are holding an export controls and sanctions conference at our London offices on 09 November 2017.