Waive it Goodbye? How the Trump Administration Might Attack the JCPOA

February 4, 2017
By Anthony Rapa*

President Trump has made no effort to conceal his disdain for the Joint Comprehensive Plan of Action (JCPOA) agreement regarding Iran’s nuclear program, which he frequently has described as a “disaster” ranking among the worst deals in U.S. history. However, heated rhetoric notwithstanding, he often spoke on the campaign trail of improving the deal, rather than tearing it up. While the Administration has not yet advanced any specific policy regarding the JCPOA, and while future developments remain difficult to predict, the President may seek to ramp up pressure on Iran within the framework of the existing agreement, rather than repudiate the deal altogether. As the President himself explained when he was a candidate: “We have a horrible contract, but we do have a contract.” (more…)

OFAC Issues General License Effectively Lifting Sudan Sanctions

February 3, 2017
By: Michelle Turner Roberts, Dan Fisher-Owens, Ben Flowe, Perry Bechky, Babak Hoghooghi, Ray Gold, John Ordway, and Jason McClurg*

With a stroke of his pen on January 13, 2017, by Executive Order 13761, President Obama effectively lifted the Sudan Sanctions, in recognition of the Government of Sudan’s progress in reducing offensive military action, improving humanitarian access, and cooperating with the United States in counter-terrorism efforts. (more…)

India’s Upgrade in Export Control Status and Bid to Enter ‘Dual Use’ Controls Club Point to Expansion of Non-Proliferation Efforts

February 2, 2017
By: Anna Sayre, Legal Content Writer, SanctionsAlert.com

On January 19, 2017, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) to implement a new phase of export control cooperation between the U.S. and India.

The new rule marked the first major change to India’s “Validated End User” (VEU) status since July 2009 and follows recognition of India by BIS as a “Major Defense Partner” on June 7, 2016. (more…)

What to Expect for Economic Sanctions Under President Trump?

January 13, 2017
By Anthony Rapa, Alexis Early and Peter Jeydel*

President-elect Trump has made bold and surprising pronouncements about what he may do after January 20 in the field of international affairs, and these foreign policy choices are likely to have a significant impact on the future course of U.S. economic sanctions programs targeting Iran, Cuba, Russia and other areas. Mr. Trump has said he would terminate the Iran nuclear deal, and with it the sanctions rollback that has taken place over the past year, although actually convincing the rest of the world to re-impose sanctions on Iran would be a monumental feat of diplomacy.  On Cuba, Mr. Trump has given reasonably clear signals both that he would support the recent easing of sanctions and that he would reverse it, so the actual policy of the incoming Administration is hardly better than a 50/50 guess at this stage, though with the odds slightly favoring some tightening of sanctions.  Russia may be different.  That is one area in which Mr. Trump’s statements and actions point to a real possibility of a wholesale change in U.S. policy, although bipartisan congressional concerns with Russia may present a major obstacle to radically changing the current state of affairs, at least without significant concessions by Russia. (more…)