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December 10, 2013

MASSACHUSETTS EXPORT CENTER EXPORT EXPO Hot Topics in Export Compliance: Trade Sanctions Developments. December 10, 2013. Lise S. Test, Associate Baker & McKenzie LLP Washington, DC. Iran Update. Iran Nuclear Programme deal Very limited suspension of sanctions

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December 10, 2013

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  1. MASSACHUSETTS EXPORT CENTEREXPORT EXPOHot Topics in Export Compliance: Trade Sanctions Developments December 10, 2013 Lise S. Test, Associate Baker & McKenzie LLP Washington, DC

  2. Iran Update • Iran Nuclear Programme deal • Very limited suspension of sanctions • Effective October 9, 2012, owned/controlled foreign affiliates of U.S. persons are fully subject to the OFAC sanctions against Iran • Owned/controlled affiliates can rely on same exemptions and general licenses as their U.S. parents

  3. Iran Update (cont’d) • October 22, 2012 - reissuance of Iranian Transactions Regulations to Iranian Transactions and Sanctions Regulations • Represents major overhaul of the regulations • New general license and authorized payment term for Ag/Med transactions • New limitations on funds transfers • “Payments or transfers of funds” are excluded from the scope of “ordinarily incident and necessary” (ITSR 560.405) • Practical effect is that you must find general or specific license that expressly authorizes your payment activities (e.g., 560.530/532 anfd 560.516)

  4. Iran Update (cont’d) • SEC disclosure requirements for “knowingly” engaging in certain activitites, most of which target Iran • No materiality threshold • Few exceptions to disclosure • General License D for certain exports incident to the exchange of personal communications • General License D is in addition to the general license in 560.540 (which authorizes exports free of charge that were incident to the exchange of personal communications)

  5. Burma/Myanmar Update • “New investment” reporting requirement to the State Department • USD 500,000 threshold – “over any period” • Only applies to U.S. persons making “new investments” • Does not apply to U.S. persons “facilitating” “new investments” • Imports no longer prohibited, except jadeite and rubies • General License No. 19 • Asia Green Development Bank, Ayeyarwady Bank, Myanma Economic Bank, Myanma Investment and Commercial Bank • Banks remain on SDN list but can be used for nearly all financial transactions

  6. Questions? Contact Information: Lise Test Associate Baker & McKenzie LLP Phone: (202) 835-6131 Email: lise.test@bakermckenzie.com :

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