3rd part of a perfect overview on economic sanctions made by Marian Dent from Pericles. Covers following sections: SSI Lists, OFAC Directive 4, Export Administration Regulations, Dual use technologies, European export controls, other countries imposing sanctions (UK, Canada, Switzerland, Norway, Japan, Australia), Contracts, Compliance and Damage Control
This document is a superseding indictment charging multiple individuals and entities with conspiracy to violate export control laws. It alleges that the defendants conspired to export a power turbine from the US to a Russian state-owned company, requiring an export license, without obtaining the necessary license from the Department of Commerce. The Russian company was on the Entity List for export restrictions. The indictment charges the defendants with conspiracy to commit offenses against the US in violating export control laws.
Ukraine and russian_sanctions shipping - sept 1Andrew Gelston
The document summarizes sanctions imposed by the European Union, United States, and Russia in response to Russia's annexation of Crimea and Sevastopol from Ukraine. Key points include:
- The EU and US have frozen assets of designated persons and entities involved, and prohibited certain financial transactions.
- The EU has also banned imports from Crimea/Sevastopol, and sales of certain goods and technology to areas under Russian control.
- Russia responded with a ban on many agricultural imports from countries that sanctioned it.
- Members are advised sanctions laws are complex and to seek legal counsel, as breaching sanctions could jeopardize their insurance coverage.
Министерствам и ведомствам США с завтрашнего дня запрещено заключать любые контракты с компаниями из обнародованного списка и оказывать им любую материальную поддержку.
This document summarizes United States Forces Korea Regulation 60-1, which establishes policies for authorized access to duty-free goods in South Korea. Key points include:
- Setting purchase limits for alcohol, beer, and commissary goods to prevent abuse of duty-free privileges.
- Requiring registration in the Defense Biometric Identification System and possessing a ration control card for access to duty-free facilities.
- Authorizing access only to personnel allowed under the US-ROK Status of Forces Agreement, including military, civilian employees, contractors, and their families.
- Establishing responsibilities for various offices to monitor purchasing trends, issue ration cards, train staff, and take action against violations.
AFC International, LLC, a Customs Brokerage firm located in Atlanta, Georgia, explains the Importer Security Filing (ISF) regulation, recent changes to the regulation, and what you need to know when importing to the U.S.
Civil aviation act 1969 (akta penerbangan awam)Aaron Teh
This document is the Civil Aviation Act 1969 of Malaysia. It establishes the legal framework for regulating civil aviation in Malaysia. Key aspects include:
- Establishing the position of Director General of Civil Aviation Malaysia and outlining their duties of regulating civil aviation, representing the government on aviation matters, and ensuring safety and development of the industry.
- Regulating the establishment and operation of aerodromes in Malaysia by both the government and private companies.
- Establishing a Civil Aviation Fund to support the development and maintenance of aviation infrastructure.
- Controlling obstructions near aerodromes for safety reasons.
- Addressing liability for damage caused by aircraft.
- Detention of aircraft under certain conditions
Pavel Antonov, Head of Legal Operations at Accountor Russia, shed light on the legal side of the sanctions issue, covering the following topics: practical meaning of sanctions for foreign companies, restrictions for business deals (legal consequences for businesses & individuals), measures to be taken for legal compliance and avoiding risks, and business in the Crimea – what is allowed and what is not?
This document is a superseding indictment charging multiple individuals and entities with conspiracy to violate export control laws. It alleges that the defendants conspired to export a power turbine from the US to a Russian state-owned company, requiring an export license, without obtaining the necessary license from the Department of Commerce. The Russian company was on the Entity List for export restrictions. The indictment charges the defendants with conspiracy to commit offenses against the US in violating export control laws.
Ukraine and russian_sanctions shipping - sept 1Andrew Gelston
The document summarizes sanctions imposed by the European Union, United States, and Russia in response to Russia's annexation of Crimea and Sevastopol from Ukraine. Key points include:
- The EU and US have frozen assets of designated persons and entities involved, and prohibited certain financial transactions.
- The EU has also banned imports from Crimea/Sevastopol, and sales of certain goods and technology to areas under Russian control.
- Russia responded with a ban on many agricultural imports from countries that sanctioned it.
- Members are advised sanctions laws are complex and to seek legal counsel, as breaching sanctions could jeopardize their insurance coverage.
Министерствам и ведомствам США с завтрашнего дня запрещено заключать любые контракты с компаниями из обнародованного списка и оказывать им любую материальную поддержку.
This document summarizes United States Forces Korea Regulation 60-1, which establishes policies for authorized access to duty-free goods in South Korea. Key points include:
- Setting purchase limits for alcohol, beer, and commissary goods to prevent abuse of duty-free privileges.
- Requiring registration in the Defense Biometric Identification System and possessing a ration control card for access to duty-free facilities.
- Authorizing access only to personnel allowed under the US-ROK Status of Forces Agreement, including military, civilian employees, contractors, and their families.
- Establishing responsibilities for various offices to monitor purchasing trends, issue ration cards, train staff, and take action against violations.
AFC International, LLC, a Customs Brokerage firm located in Atlanta, Georgia, explains the Importer Security Filing (ISF) regulation, recent changes to the regulation, and what you need to know when importing to the U.S.
Civil aviation act 1969 (akta penerbangan awam)Aaron Teh
This document is the Civil Aviation Act 1969 of Malaysia. It establishes the legal framework for regulating civil aviation in Malaysia. Key aspects include:
- Establishing the position of Director General of Civil Aviation Malaysia and outlining their duties of regulating civil aviation, representing the government on aviation matters, and ensuring safety and development of the industry.
- Regulating the establishment and operation of aerodromes in Malaysia by both the government and private companies.
- Establishing a Civil Aviation Fund to support the development and maintenance of aviation infrastructure.
- Controlling obstructions near aerodromes for safety reasons.
- Addressing liability for damage caused by aircraft.
- Detention of aircraft under certain conditions
Pavel Antonov, Head of Legal Operations at Accountor Russia, shed light on the legal side of the sanctions issue, covering the following topics: practical meaning of sanctions for foreign companies, restrictions for business deals (legal consequences for businesses & individuals), measures to be taken for legal compliance and avoiding risks, and business in the Crimea – what is allowed and what is not?
THE REGULATORY APPROACH TO HEALTH SAFETY AND ENVIRONMENT IN IRELANDADEGOKE OSHUNNIYI
The Irish approach to regulating health, safety and the environment in the oil and gas sector has evolved over time. It was initially influenced by the UK model and EU directives. The current risk-based, permissioning approach is outlined in the 2015 Petroleum (Exploration and Extraction) Safety Act, which transposes the EU Offshore Safety Directive. This act gives the Commission for Energy Regulation the authority to implement a risk-based Petroleum Safety Framework and require safety permits and cases that reduce risks to as low as reasonably practicable. The regulatory approach has shifted from a prescriptive one in early legislation to the current goal-setting, permission-based system centered around risk assessment and ALARP principles.
This document provides an overview of Introduction From the Sea (IFS), one of the four types of trade regulated by CITES. IFS involves the transportation into a state of specimens taken from the marine environment beyond any state's jurisdiction (known as the high seas). The document discusses what constitutes IFS, the permitting requirements for IFS of Appendix I and II specimens, areas for further work, and the relationship between IFS and other international agreements and bodies like CITES, RFMOs, FAO, and UNCLOS.
This document is the Import Policy Order 2009 issued by the Government of Pakistan. Some key points:
- It establishes rules for imports into Pakistan, including definitions of key terms, allowed bases for imports, general rules on allowed/banned/restricted goods, and certain import restrictions.
- Appendix A lists banned goods, Appendix B lists goods importable with conditions, and Appendix C bans imports of certain secondhand/used goods.
- Certain goods from countries like Israel, BSE-infected countries, and countries with avian influenza are prohibited from import.
- Used machinery and equipment imports are allowed under certain conditions like age limits and inspection certification.
- Temporary imports are allowed for certain sectors like construction
The U.S. Department of State determined that a number of foreign persons engaged in activities that warrant nonproliferation measures under the Iran, North Korea, and Syria Nonproliferation Act. These measures include a ban on U.S. government procurement from and assistance to 33 named foreign entities from countries including Belarus, China, Iran, Iraq, Malaysia, North Korea, Russia, Sudan, Syria and Uganda. The bans will remain in place for two years unless the Secretary of State determines otherwise.
This document is the text of H.R. 6156, the Russia and Moldova Jackson-Vanik Repeal and Sergei Magnitsky Rule of Law Accountability Act of 2012. The bill has four titles: I) it would terminate the application of the Jackson-Vanik amendment to Russia and grant it permanent normal trade relations; II) it establishes reporting requirements for Russia's WTO compliance and allows the USTR to take enforcement actions; III) it similarly grants permanent normal trade relations to Moldova; and IV) it establishes the Sergei Magnitsky Rule of Law Accountability Act targeting human rights abusers in Russia.
Infographic | The Evolution of ComplicationLabelmaster
Today’s fast-paced world may bear little resemblance to the 1860s, but the safe shipping of Dangerous Goods was every bit as important then as it is now. This infographic provides a brief retrospective on the key milestones and government agencies that have shaped US shipping regulations over the past 100+ years.
The SkyLIFE company develops aerial delivery systems to transport humanitarian aid to remote and difficult to access areas. Their products include the SkyLIFE Pack, Ballute Delivery System, and Digital Audio Media System. SkyLIFE has partnered with organizations like the United Nations World Food Programme and US Special Operations Command to provide their systems for humanitarian aid missions. They have also applied for patents in many countries and are seeking to expand their partnerships and production through a long-term agreement with the UN.
This document outlines the Special Economic Zones Rules from 2006 incorporating amendments up to July 2010. [1] It begins by providing definitions for key terms related to Special Economic Zones (SEZs) such as capital goods, raw materials, infrastructure, authorized officer, specified officer, and more. [2] It then outlines the procedure for establishing an SEZ, stating that any proposal to set up an SEZ must be submitted in Form A to the concerned Development Commissioner, who will forward it to the Board within 15 days along with an inspection report and state government recommendation.
The document provides information about a public meeting to discuss the impact of the Chemical Weapons Convention (CWC) on commercial activities involving "Schedule 1" chemicals. It announces the meeting date and agenda, provides call-in details, and requests public comments. BIS will use the comments to prepare its annual certification to Congress that legitimate commercial interests are not being harmed by CWC implementation. The meeting will include discussions on project planning, other business, and the next meeting date. Public comments may be submitted by mail or email.
Bangladesh parliament passed the Finance Bill 2019 with some changes in value-added tax (VAT) and in the policy of capital market and handloom industry
Speaker 1 - Responsibility of Stake Holders under MLCcmmindia2017
The document discusses the Maritime Labour Convention 2006 (MLC) and its implementation in India. Some key points:
- The MLC aims to promote decent work conditions for seafarers and came into force globally in 2013. India ratified it and put mechanisms in place for compliance.
- The MLC covers areas like minimum requirements for seafarers, conditions of employment, accommodation, recreational facilities, food and catering, health protection, medical care, welfare, and social security.
- India implemented the MLC through rules covering areas like seafarer accommodation, recruitment and placement, medical examinations, and general maritime labor.
- Statistics on inspections show most deficiencies found relate
This document provides comments on proposed amendments to US Munitions List Category IV. It notes that the proposed rules would subject both classified and unclassified technical data related to certain items to different export control jurisdictions, potentially requiring multiple licenses. It argues clearer lines are needed to determine when Commerce Department vs State Department licenses are required, especially for partial vs complete sets of technical data. It also questions how the proposed rules would treat segregation or redaction of technical data related to specific components.
This document is a bill introduced in the Senate to amend the Federal Food, Drug, and Cosmetic Act regarding human drug compounding and drug supply chain security. Title I of the bill focuses on drug compounding, establishing requirements for outsourcing facilities that compound drugs, including registration, reporting, labeling, and inspection. Title II addresses drug supply chain security, proposing national standards for drug distribution and third-party logistics providers.
The document discusses using social media for Toastmasters club marketing and membership building. It provides details on top social media sites like Facebook, Twitter, LinkedIn and MySpace and how each can be used. The document emphasizes having the right mindset when using social media by sharing expertise, building trust, driving traffic to your website, keeping an open mind and engaging followers. It also stresses that one marketing approach does not fit all.
The document is about Epsilon Nu Tau Fraternity, an organization that creates networks and provides experiences to help students launch sustainable businesses. The fraternity's purposes are to create an entrepreneurially-spirited community, advance professionalism and sales ideals, promote entrepreneurship, and encourage ethical business practices. It has regional chapters at several universities and promotes an entrepreneurial mindset through professional events, social activities, and community support.
This document discusses considerations for building a mobile application. It notes that mobile apps are expected to look like numbers, news and forms but can result in frustration during development. The document emphasizes understanding your users and the platforms they will use the app on. It provides an overview of options like developing native apps for each platform or creating hybrid apps that use web views. The document also touches on topics like app stores, marketing, security, and authentication.
Créez votre cours en ligne flyer automneFormation 3.0
Vous avez envie de devenir formateur / formatrice à distance et vous ne savez pas trop par où commencer ? Vous voudriez passer au e-learning, mais vous avez besoin d'accompagnement pour démarrer ?
Cette formation en ligne est faite pour vous ! Notre SPOC en est à sa quatrième édition et s'enrichit à chaque session.
Avec "Créez votre cours en ligne", vous apprendrez à identifier votre public, à répondre à ses besoins de manière efficace en suivant les principes du design thinking ; vous scénariserez vos formations en professionnel, vous créerez des supports de formation à distance pertinents et vous mettrez votre propre cours en ligne à la fin des 5 semaines.
N'attendez plus et inscrivez-vous vite à notre formation en ligne !
This document summarizes a proposed study that aims to investigate the effects of subliminal/supraliminal presentation and shallow/deep levels of processing on explicit memory performance in older adults. The study uses a 2x2 within-subjects design to manipulate presentation type (subliminal vs supraliminal) and level of processing (shallow vs deep). It is hypothesized that deep processing combined with subliminal presentation will yield the highest memory performance scores. Around 50 older adult participants will complete a memory task involving word lists under the different conditions. Their memory will be assessed using a recognition test.
Social Media Revolution_Luis Ongil_Working SpaceWorking Space
El documento habla sobre la revolución de los medios sociales y cómo las empresas pueden aprovechar plataformas como Facebook y Twitter. Menciona que los consumidores ahora controlan el mensaje a través del boca a boca instantáneo en estas redes y que las compañías deben inspirar pasión en sus comunidades en línea en lugar de usarlas solo para ventas. También da consejos sobre cómo crear páginas en Facebook que sean humanas y conecten con las personas para construir una comunidad leal.
THE REGULATORY APPROACH TO HEALTH SAFETY AND ENVIRONMENT IN IRELANDADEGOKE OSHUNNIYI
The Irish approach to regulating health, safety and the environment in the oil and gas sector has evolved over time. It was initially influenced by the UK model and EU directives. The current risk-based, permissioning approach is outlined in the 2015 Petroleum (Exploration and Extraction) Safety Act, which transposes the EU Offshore Safety Directive. This act gives the Commission for Energy Regulation the authority to implement a risk-based Petroleum Safety Framework and require safety permits and cases that reduce risks to as low as reasonably practicable. The regulatory approach has shifted from a prescriptive one in early legislation to the current goal-setting, permission-based system centered around risk assessment and ALARP principles.
This document provides an overview of Introduction From the Sea (IFS), one of the four types of trade regulated by CITES. IFS involves the transportation into a state of specimens taken from the marine environment beyond any state's jurisdiction (known as the high seas). The document discusses what constitutes IFS, the permitting requirements for IFS of Appendix I and II specimens, areas for further work, and the relationship between IFS and other international agreements and bodies like CITES, RFMOs, FAO, and UNCLOS.
This document is the Import Policy Order 2009 issued by the Government of Pakistan. Some key points:
- It establishes rules for imports into Pakistan, including definitions of key terms, allowed bases for imports, general rules on allowed/banned/restricted goods, and certain import restrictions.
- Appendix A lists banned goods, Appendix B lists goods importable with conditions, and Appendix C bans imports of certain secondhand/used goods.
- Certain goods from countries like Israel, BSE-infected countries, and countries with avian influenza are prohibited from import.
- Used machinery and equipment imports are allowed under certain conditions like age limits and inspection certification.
- Temporary imports are allowed for certain sectors like construction
The U.S. Department of State determined that a number of foreign persons engaged in activities that warrant nonproliferation measures under the Iran, North Korea, and Syria Nonproliferation Act. These measures include a ban on U.S. government procurement from and assistance to 33 named foreign entities from countries including Belarus, China, Iran, Iraq, Malaysia, North Korea, Russia, Sudan, Syria and Uganda. The bans will remain in place for two years unless the Secretary of State determines otherwise.
This document is the text of H.R. 6156, the Russia and Moldova Jackson-Vanik Repeal and Sergei Magnitsky Rule of Law Accountability Act of 2012. The bill has four titles: I) it would terminate the application of the Jackson-Vanik amendment to Russia and grant it permanent normal trade relations; II) it establishes reporting requirements for Russia's WTO compliance and allows the USTR to take enforcement actions; III) it similarly grants permanent normal trade relations to Moldova; and IV) it establishes the Sergei Magnitsky Rule of Law Accountability Act targeting human rights abusers in Russia.
Infographic | The Evolution of ComplicationLabelmaster
Today’s fast-paced world may bear little resemblance to the 1860s, but the safe shipping of Dangerous Goods was every bit as important then as it is now. This infographic provides a brief retrospective on the key milestones and government agencies that have shaped US shipping regulations over the past 100+ years.
The SkyLIFE company develops aerial delivery systems to transport humanitarian aid to remote and difficult to access areas. Their products include the SkyLIFE Pack, Ballute Delivery System, and Digital Audio Media System. SkyLIFE has partnered with organizations like the United Nations World Food Programme and US Special Operations Command to provide their systems for humanitarian aid missions. They have also applied for patents in many countries and are seeking to expand their partnerships and production through a long-term agreement with the UN.
This document outlines the Special Economic Zones Rules from 2006 incorporating amendments up to July 2010. [1] It begins by providing definitions for key terms related to Special Economic Zones (SEZs) such as capital goods, raw materials, infrastructure, authorized officer, specified officer, and more. [2] It then outlines the procedure for establishing an SEZ, stating that any proposal to set up an SEZ must be submitted in Form A to the concerned Development Commissioner, who will forward it to the Board within 15 days along with an inspection report and state government recommendation.
The document provides information about a public meeting to discuss the impact of the Chemical Weapons Convention (CWC) on commercial activities involving "Schedule 1" chemicals. It announces the meeting date and agenda, provides call-in details, and requests public comments. BIS will use the comments to prepare its annual certification to Congress that legitimate commercial interests are not being harmed by CWC implementation. The meeting will include discussions on project planning, other business, and the next meeting date. Public comments may be submitted by mail or email.
Bangladesh parliament passed the Finance Bill 2019 with some changes in value-added tax (VAT) and in the policy of capital market and handloom industry
Speaker 1 - Responsibility of Stake Holders under MLCcmmindia2017
The document discusses the Maritime Labour Convention 2006 (MLC) and its implementation in India. Some key points:
- The MLC aims to promote decent work conditions for seafarers and came into force globally in 2013. India ratified it and put mechanisms in place for compliance.
- The MLC covers areas like minimum requirements for seafarers, conditions of employment, accommodation, recreational facilities, food and catering, health protection, medical care, welfare, and social security.
- India implemented the MLC through rules covering areas like seafarer accommodation, recruitment and placement, medical examinations, and general maritime labor.
- Statistics on inspections show most deficiencies found relate
This document provides comments on proposed amendments to US Munitions List Category IV. It notes that the proposed rules would subject both classified and unclassified technical data related to certain items to different export control jurisdictions, potentially requiring multiple licenses. It argues clearer lines are needed to determine when Commerce Department vs State Department licenses are required, especially for partial vs complete sets of technical data. It also questions how the proposed rules would treat segregation or redaction of technical data related to specific components.
This document is a bill introduced in the Senate to amend the Federal Food, Drug, and Cosmetic Act regarding human drug compounding and drug supply chain security. Title I of the bill focuses on drug compounding, establishing requirements for outsourcing facilities that compound drugs, including registration, reporting, labeling, and inspection. Title II addresses drug supply chain security, proposing national standards for drug distribution and third-party logistics providers.
The document discusses using social media for Toastmasters club marketing and membership building. It provides details on top social media sites like Facebook, Twitter, LinkedIn and MySpace and how each can be used. The document emphasizes having the right mindset when using social media by sharing expertise, building trust, driving traffic to your website, keeping an open mind and engaging followers. It also stresses that one marketing approach does not fit all.
The document is about Epsilon Nu Tau Fraternity, an organization that creates networks and provides experiences to help students launch sustainable businesses. The fraternity's purposes are to create an entrepreneurially-spirited community, advance professionalism and sales ideals, promote entrepreneurship, and encourage ethical business practices. It has regional chapters at several universities and promotes an entrepreneurial mindset through professional events, social activities, and community support.
This document discusses considerations for building a mobile application. It notes that mobile apps are expected to look like numbers, news and forms but can result in frustration during development. The document emphasizes understanding your users and the platforms they will use the app on. It provides an overview of options like developing native apps for each platform or creating hybrid apps that use web views. The document also touches on topics like app stores, marketing, security, and authentication.
Créez votre cours en ligne flyer automneFormation 3.0
Vous avez envie de devenir formateur / formatrice à distance et vous ne savez pas trop par où commencer ? Vous voudriez passer au e-learning, mais vous avez besoin d'accompagnement pour démarrer ?
Cette formation en ligne est faite pour vous ! Notre SPOC en est à sa quatrième édition et s'enrichit à chaque session.
Avec "Créez votre cours en ligne", vous apprendrez à identifier votre public, à répondre à ses besoins de manière efficace en suivant les principes du design thinking ; vous scénariserez vos formations en professionnel, vous créerez des supports de formation à distance pertinents et vous mettrez votre propre cours en ligne à la fin des 5 semaines.
N'attendez plus et inscrivez-vous vite à notre formation en ligne !
This document summarizes a proposed study that aims to investigate the effects of subliminal/supraliminal presentation and shallow/deep levels of processing on explicit memory performance in older adults. The study uses a 2x2 within-subjects design to manipulate presentation type (subliminal vs supraliminal) and level of processing (shallow vs deep). It is hypothesized that deep processing combined with subliminal presentation will yield the highest memory performance scores. Around 50 older adult participants will complete a memory task involving word lists under the different conditions. Their memory will be assessed using a recognition test.
Social Media Revolution_Luis Ongil_Working SpaceWorking Space
El documento habla sobre la revolución de los medios sociales y cómo las empresas pueden aprovechar plataformas como Facebook y Twitter. Menciona que los consumidores ahora controlan el mensaje a través del boca a boca instantáneo en estas redes y que las compañías deben inspirar pasión en sus comunidades en línea en lugar de usarlas solo para ventas. También da consejos sobre cómo crear páginas en Facebook que sean humanas y conecten con las personas para construir una comunidad leal.
Morgan Manley enjoys sports, especially softball and volleyball, which have been a big part of her life. While the biography does not provide details on her favorite famous people or places, it includes some personal photos of Morgan.
This document discusses entrepreneurship and provides guidance for women considering starting their own business. It notes that women are starting businesses at twice the rate of men and often solve workplace issues. Successful entrepreneurs tend to be problem-solvers, independent, and persistence in facing obstacles. However, women face barriers like lack of networks, funding, and childcare. The document provides tips for overcoming barriers, creating a one-page business plan, projecting revenues, and working the business plan. Resources from Ladies Who Launch and other organizations are recommended for support.
Libro X es un software de administración bibliográfica que permite a los usuarios acceder fácilmente a la base de datos de la biblioteca desde cualquier lugar a través de un portal web. Ofrece módulos para la administración de datos, circulación, catalogación y búsqueda de colecciones. También incluye un programa institucional llamado BID para crear un sistema de consulta y publicación de documentos generados por profesores y estudiantes del SENA.
pp.16-19 - Article on WTO - loan calculator magazinePavel Melnikov
Вступление России в ВТО: мнение представителей бизнеса и экспертов
Россия стала полноправным членом ВТО 22 августа 2012 года. В январе 2013 года коммуникационное агентство Grayling выпустило исследование «Восприятие последствий присоединения России к ВТО бизнесом и экспертным сообществом» . В нем была сделана попытка подвести первые итоги вступления России в ВТО глазами профессионалов и экспертов рынка: тех, кто занимался изучением вопросов, связанных с ВТО, и тех, кого изменения касаются напрямую. Тема восприятия последствий вступления России в ВТО бизнесом и экспертным сообществом была выбрана именно по причине ее неоднозначности.
The document discusses the importance of providing effective feedback to high performing teams. It states that feedback is crucial for success and motivation, and cites studies showing that lack of feedback is a top reason why employees leave jobs. The document recommends using the AID model for feedback, which stands for Action, Impact, and Do. For the Action, the feedback provider should clearly describe the observed behavior. For the Impact, they should explain how the behavior impacted them. For the Do, they should suggest actions the receiver can take as a result of the feedback. The document provides tips for both giving and receiving feedback effectively.
Perkembangan asuransi syariah di indonesia 2012Wiku Suryomurti
1) The development of Islamic insurance in Indonesia has seen significant growth in recent years in terms of market share and asset growth.
2) Indonesia has developed a comprehensive Islamic financial system over the past two decades that includes banking, insurance, sukuk bonds, and capital markets.
3) Data shows that from 2010-2011, the top Islamic insurance companies experienced a substantial increase in written premiums, assets, investments and profits.
El documento enfatiza que la vida no debe ser entendida sino vivida, aprovechando cada momento. Aunque a veces pasamos años sin vivir, la vida se puede concentrar en un solo instante. Es importante estar preparado y saber esperar el momento adecuado para actuar, en lugar de posponer las cosas para el mañana y perder el día de hoy. A pesar de las tormentas, siempre hay esperanza de reconstruir la vida si ponemos coraje y esfuerzo.
The document discusses linear regression and regularization. It introduces linear regression models using basis functions and describes optimization methods like gradient descent. It then covers regularization, discussing how adding constraints like lasso and ridge regression can improve generalization by reducing overfitting. The document presents evidence selection methods like Bayesian model averaging to integrate over models. Finally, it describes applying empirical Bayes methods to estimate hyperparameters like α and β by maximizing the marginal likelihood.
This document provides an overview of intellectual property issues related to the handicraft industry in India. It discusses the importance of traditional knowledge to handicraft artisans in India. It then analyzes the Indian handicraft industry and describes how the Design Act of 2000 in India allows registration of industrial designs for copyright protection. The document also provides a profile of A.V. Inc., the leading handicraft manufacturer and exporter that will be analyzed for its intellectual property management practices.
Why does the UK impose export controls?
What is controlled (and what is not)?
How does the licensing process work?
What are the different types of licence?
How are the controls enforced, what are the penalties?
How to avoid delays and risks in export licensing?
How BIS and Green Light Exports can provide help.
MARPOL Annex VI aims to reduce air pollution from ships. It regulates emissions of sulfur oxides, nitrogen oxides, particulate matter, and ozone depleting substances. The regulations establish emission control areas with more stringent standards for emissions of sulfur oxides and particulate matter. Ships must use low-sulfur fuel in these areas and meet emission limits for nitrogen oxides that become increasingly strict over time. Compliance is demonstrated through certification and testing of engines and fuels.
This document contains summaries of chapters and regulations from MARPOL Annex VI, which sets limits on air pollutants from ships and includes regulations for controlling emissions. It includes definitions of key terms, such as emission control area, marine diesel engine, and defeat device. The document also notes that the provisions apply to all ships, except where expressly exempted. It contains summaries of the general provisions as well as the first chapter on general regulations, including definitions.
The document summarizes regulations established by the US Coast Guard regarding ballast water management reporting for vessels entering US ports. It notes that civil penalties up to $27,500 may be assessed for failing to submit ballast water management reports, as required by law. It also indicates that the regulations are intended to help prevent the introduction of invasive species. The document provides additional context and clarification on the regulations for mobile offshore drilling units operating in US waters.
The document summarizes the key aspects of the 1974 SOLAS Convention, including its history and amendments. The main points are:
1. SOLAS 1974 consolidated earlier conventions and introduced a new amendment procedure to allow for timely updates. It aims to specify minimum safety standards for ship construction and equipment.
2. Amendments are adopted through the IMO's Maritime Safety Committee or by a conference if requested by enough countries.
3. The convention contains 12 chapters covering matters like ship construction, lifesaving appliances, dangerous cargo carriage, and safety management.
4. Ships must undergo periodic surveys to obtain certificates of compliance which are valid for periods ranging from 12-60 months depending on type.
The document discusses key aspects of the 1974 International Convention for the Safety of Life at Sea (SOLAS), as amended. It outlines the history and amendment procedures of SOLAS. The main objective of SOLAS is to specify minimum standards for ship construction and safety equipment. The document then summarizes each of the 12 chapters of SOLAS, including requirements for ship construction, fire protection, life-saving appliances, navigation safety, dangerous cargo carriage, and security measures. It concludes by discussing the various safety certificates issued in accordance with SOLAS and the role of classification societies.
The document discusses decommissioning regulations and cost provisions in Ireland for offshore oil and gas installations. It notes that under Irish law, the authorisation holder is responsible for decommissioning costs. For planned decommissioning, they must obtain a decommissioning safety permit by submitting an approved decommissioning safety case outlining the process. The safety case must demonstrate how risks will be reduced to a level that is as low as reasonably practicable. The document also examines the relevant licensing terms that apply to different offshore blocks in Ireland and notes provisions regarding abandonment of installations.
The document provides an overview of MARPOL, the International Convention for the Prevention of Pollution from Ships. MARPOL includes six annexes that establish regulations for preventing various forms of pollution from ships. It was adopted in 1973 and amended in 1978, and entered into force in 1983. The annexes address pollution by oil, noxious liquid substances, harmful packaged substances, sewage, garbage, and air pollutants. The annexes also designate certain sea areas as special areas with more stringent discharge requirements.
Segment 001 of Segment 002 of IELR15_5_187-224Michael Davar
This document provides an overview of decommissioning in the UK Continental Shelf from a litigator's perspective. It discusses that as oil fields age, decommissioning becomes necessary to remove installations safely. The regulatory framework in the UK requires full removal of installations. Decommissioning the 350 active fields in the UKCS is estimated to cost over £35 billion. This level of spending provides opportunities for companies to develop expertise in heavy lifting and other decommissioning services. The document also analyzes potential areas of litigation regarding decommissioning, such as challenges to notices requiring parties to carry out decommissioning and claims related to delays, pollution, contracts, and insurance.
The SOLAS 74 convention is the key international maritime treaty that sets baseline safety standards for the construction, equipment and operation of ships. It has been updated numerous times since first adopted in 1974. The convention includes 12 chapters that address topics like ship construction, lifesaving appliances, radiocommunications, safety of navigation, dangerous cargo carriage, and management for safe ship operation. It requires ships to be surveyed and certificated to verify compliance with SOLAS standards. Major codes made mandatory under SOLAS include the ISM code for ship management and specialty codes for chemical tankers and gas carriers.
This document discusses MARPOL Annex VI and emissions control from ships. It provides information on key regulations including the ratification process for Annex VI, regulated emissions from ships, and regulations on ozone depleting substances, nitrogen oxides, sulfur oxides, and reception facilities for ship emissions. It also summarizes certification and compliance requirements for ships and engines.
The International Convention for the Safety of Life at Sea, 1974 (SOlAS), as amended, deals with various aspects of
maritime safety and contains in part A of chapter VII the mandatory provisions governing the carriage of dangerous goods in
packaged form or in solid form in bulk. Regulation VII/1.3 prohibits the carriage of dangerous goods except in accordance
with the provisions of part A of chapter VII, which are amplified by the International Maritime Dangerous Goods (IMDG)
Code.
Regulation 11-2/19 of the SOlAS Convention, as amended, specifies the special requirements for a ship intended to carry
dangerous goods, the keel of which was laid or which was at a similar stage of construction on or after 1 July 2002.
The International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating
thereto (MAR POL 73/78), deals with various aspects of prevention of marine pollution, and contains in its Annex III the
mandatory provisions for the prevention of pollution by harmful substances carried by sea in packaged form. Regulation 1 (2)
prohibits the carriage of harmful substances in ships except in accordance with the provisions of Annex III, which are also
amplified by the IMDG Code.
South Africa intends to accede to Annexes IV and VI of the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). Annex IV regulates the discharge of sewage from ships and Annex VI regulates air pollution from ships. South Africa's key obligations under these annexes would be to ensure that its vessels comply with technical standards and undergo periodic inspections and surveys. Various stakeholders support accession and there are no significant financial, security, or communication implications. The acting director-general recommends that the transport committee note South Africa's intention to accede and approve submitting the annexes to Parliament.
South Africa intends to accede to Annexes IV and VI of the International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). Annex IV regulates the discharge of sewage from ships and Annex VI regulates air pollution from ships. South Africa's key obligations under these annexes would be to ensure that its vessels comply with technical standards and undergo periodic inspections and surveys. Various stakeholders support accession and do not foresee significant financial or security implications. The presentation recommends that the transport committee note South Africa's intention to accede and approve submitting the annexes to Parliament.
This document provides draft provisions for harmonizing fishing vessel registration, construction, and safety regulations across countries. It includes proposed amendments to national fisheries acts and draft regulations. The amendments and regulations establish requirements for registering local fishing vessels, setting vessel names, issuing certificates of registration and inspection, maintaining a vessel register, and suspending or cancelling registration for non-compliance. They also require vessels to meet construction and safety standards before being registered and given a license to fish.
The document provides an introduction to the International Convention for the Safety of Life at Sea (SOLAS). It discusses the history and development of SOLAS since 1914 in response to maritime disasters. SOLAS currently consists of 12 chapters that establish minimum standards for ship construction, equipment, operation, and management. It also includes mandatory codes covering areas like fire safety, life-saving appliances, dangerous cargo carriage, and ship security. The chapters outline requirements for vessel surveys, safe navigation, emergency communications, accident prevention, and special provisions for ship types like bulk carriers and high-speed craft.
UK Ship Register permits Bareboat Charter Out - Too little, too late?Amarinder Singh Brar
1. The UK shipping register rules were recently changed to allow for "bareboat charter out" of vessels, something that was previously not permitted.
2. The changes aim to make the UK register more commercially attractive by widening eligibility and allowing owners to charter vessels out while maintaining their UK registration status.
3. However, critics argue the changes do not go far enough and owners still may find it simpler to flag out permanently rather than use the new bareboat charter out system, which requires ongoing paperwork and fees.
The document discusses decommissioning of oil and gas installations. It covers international and national legal frameworks for decommissioning, contractual provisions for decommissioning in production sharing contracts from the perspective of contractors and states, and ways that states can make international oil companies pay a share of decommissioning costs even without owning the installations. Specifically, it analyzes how some states have made contractors responsible for decommissioning costs through fiscal policies like disallowing deductions or by "ring fencing" projects to prevent cost recovery across fields.
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2. WHAT AGAINST WHOM—SSI LISTS 2
Directive 1 Finance Sector
Directive 2 Energy Sector
Directive 3 Defense Sector
Directive 4 Energy Sector Exportation or reexportation of goods, services (except financial) or tech for deepwater, Arctic offshore or shale projects
Gazprom, Gazprom Neft, Lukoil, Surgutneftegas and Rosneft
Remember this slide? For OFAC today, we are looking closely at Directive 4: Export Controls in the Energy Sector
3. 3
Directive 4 The following activities by a U.S. person or within the United States are prohibited except to the extent provided by law or unless licensed or otherwise authorized by [OFAC]: The provision, exportation or reexportation, directly or indirectly, of goods, services (except for financial services) or technology in support of exploration or production for deepwater, Arctic offshore or shale projects [hereinafter DWAOSP] that have the potential to produce oil in the [RF] or in the maritime area claimed by the [RF] and extending from its territory, and that involve any person deemed to be subject to this Directive, its property or its interests in property. [+ the usual evasion and conspiracy prohibitions]
4. 4
Gazprom, Gazprom Neft, Lukoil, Surgutneftegas and Rosneft
OFAC DIRECTIVE 4 APPLIES TO 5 COMPANIES
OFAC is part of the Department of the Treasury and deals specifically with issues related to economic sanctions regimes.
This was passed September 12
5. BIS SIMILAR YET DIFFERENT
BIS ADMINISTERS THE EAR
EAR EXISTS ALL THE TIME—EVEN WHEN SANCTIONS ARE OVER AND OFAC STOPS WORRYING ABOUT RUSSIA
BIS HAS BOTH GENERAL PROHIBITIONS AND PROHIBITIONS ON SPECIFIC ENTITIES
AUGUST 6
BIS adds Section 746.5 of EAR
BIS Adds United Shipbuilding to Entity List
SEPT 17
BIS adds 10 entities to entity list
•
5 in oil sector and only limited according to 746.5,
•
5 in defense & exports prevented entirely. 5
6. BIS SIMILAR YET DIFFERENT 6
EAR 746.5 [A] license is required to export, reexport or transfer (in-country) any item subject to the EAR listed in Supplement No. 2 to this part and items specified in ECCNs 0A998, 1C992, 3A229, 3A231, 3A232, 6A991, 8A992, and 8D999 when you know that the item will be used directly or indirectly in exploration for, or production of, oil or gas in Russian deepwater (greater than 500 feet) or Arctic offshore locations or shale formations in Russia, or are unable to determine whether the item will be used in such projects.
7. BIS SIMILAR YET DIFFERENT 7
EXAMPLE
COMMERCE CONTROL LIST (CCL) ECCNS 0A998, 1C992, 3A229, 3A231, 3A232, 6A991, 8A992, AND 8D999
8.
Directive 4 Companies
Provided end use could be DWAOSP
Gazprom;
Gazpromneft;
Lukoil;
Rosneft; and
Surgutneftegas.
First: United Shipbuilding
Next 5 More Defense Contractors for all end uses:
•
Almaz-Antey Air Defense Concern Main System Design Bureau;
•
Tikhomirov Scientific Research Institute of Instrument Design;
•
Mytishchinski Mashinostroitelny Zavod
•
Kalinin Machine Plant, JSC;
•
Dolgoprudny Research Production Enterprise. 8
REMEMBER THIS SLIDE?-EAR EL
Oil Sector
Defense Sector
Plus any export with military end uses or end users- 744.21.
9. BIS SIMILAR YET DIFFERENT
SO YOU HAVE
1) a group of export prohibitions that apply to all exports of goods for DWAOSP that has the possibility to produce oil with somewhat the same provisions applying in the OFAC regs
2) a group of export prohibitions that are the same for named oil companies
3) a group of export prohibitions for all items for named military suppliers
4) a complete prohibition of any goods for any military end uses or end users
PLUS
No savings clauses for existing contracts
•
In General License 2, OFAC gave a two week wind down for oil projects, possibly to avoid too much harm to Exxon, BIS didn’t give a wind down period, but might have given individual licenses in order to match OFAC
Former license exceptions are now over
Restricted products re-exported to Russia without a license on or after August 6 may be considered violations
Burden of Proof is on exporter to prove the end use is not DWAOSP.
NOTE: 746.5 (1) SAYS OILS AND GAS DWAOSP PROJECTS BOTH NEED A LICENSE– 746.5(2)(C) SAYS PRESUMPTION OF DENIAL IS ONLY FOR OIL PROJECTS 9
10. BIS SIMILAR YET DIFFERENT
BIS EXPORT CONTROLS ALSO CONTROL
“TRANSSHIPMENT”
General Inventory Exception
FOREIGN MADE GOODS THAT INCORPORATE US TECH
EG that uses controlled US origin software or software that is comingled with US software
FOREIGN MADE GOODS THAT ARE “DIRECT PRODUCTS” OF US TECHNOLOGY
EG a chemical agent produced in India using US patented processes.
DEMINIMUS RULE 25%
ITEMS “PASSING BACK” THROUGH US
EG items previously exported but returned for repair.
TECH INFORMATION
DEEMED EXPORTS 10
11. 11
EUROPEAN EXPORT CONTROLS
DUAL USE TECHNOLOGY: COUNCIL REG 428/2009
EACH STATE OF THE EU HAS ITS OWN REGIME FOR LICENSING EXPORTS
However, states should consult with each other
One state can request another state not to grant a license.
STATES SET PENALTIES
STATES MUST KEEP AND SHARE INFORMATION ON EXPORTS AND ON LICENSES GRANTED.
BROKERING IN ILLEGAL EXPORTS IS ITSELF ILLEGAL
12. 12
EUROPEAN EXPORT CONTROLS
EU—COUNCIL REG 833 AS AMENDED BY 960
EU GRANDFATHERS IN EXISTING CONTRACTS, FRAMEWORK AGREEMENTS & ANCILLARY CONTRACTS
NO REEXPORT, DEEMED EXPORT OR DEMINIMUS RULE (BUT MEMBER STATES?)
EU EXEMPTS NON-MILITARY AEROSPACE, EXPORTS INTENDED FOR THE MAINT. & SAFETY OF EXISTING CIVIL NUCLEAR CAPABILITIES IN EU, SERVICES FOR EVENTS THREATENING HEALTH, SAFETY, ENVIRONMENT
DIFFERENT LIST OF PROHIBITED GOODS
LIMITED LIST OF SERVICE CONTRACTS
DIFFERENT “ENTITY LIST” (ANNEX IV)
EU SPECIFICALLY INCLUDES INSURANCE & REINSURANCE
13. 13
OFAC Directive 4 The following activities by a U.S. person or within the United States are prohibited except to the extent provided by law or unless licensed or otherwise authorized by [OFAC]: The provision, exportation or reexportation, directly or indirectly, of goods, services (except for financial services) or technology in support of exploration or production for deepwater, Arctic offshore or shale projects [DWAOSP] that have the potential to produce oil in the [RF] or in the maritime area claimed by the [RF] and extending from its territory, and that involve any person deemed to be subject to this Directive, its property or its interests in property. [+ the usual evasion and conspiracy prohibitions]
RECALL OFAC DIRECTIVE 4?
14. SOME VERY PICKY EU/US DISTINCTIONS
US “DWAOSP” ARCTIC OFFSHORE AND SHALE PROJECTS WITH POTENTIAL TO PRODUCE OIL
US “IN SUPPORT OF” DWAOSP”
MARITIME AREA & EXTENDING FROM ITS TERRITORY 14
EU HAS DWOASOP (ART 3A) DEEP WATER OIL ARCTIC ___AND SHALE OIL
EU “NECESSARY FOR DWASOP.
MARITIME AREA NOT MENTIONED
It’s too early to know the significance of these differences.
16. UK SANCTIONS
Of course the EU sets the basic prohibitions.
Blocking Sanctions
Terrorist Asset Freezing Act of 2010
https://www.gov.uk/government/publications/financialsanctions- consolidated-list-of-targets
Financing Restrictions- HM Treasury tightened sanctions implementation on July 31.
Export Controls -Department of Business Innovation & Skills Export Controls Organization (UK BIZ ECO)
https://www.gov.uk/controls-on-dual-use-goods
Standard Individual Export License (SIEL) or Trade Control License (for military goods) 16
17. UK SANCTIONS FAQS
Goods listed in Annex II to Council Reg 833/2014, plus dual-use and military exports need a license
The only presumption of denial is for
goods listed in Annex II to CR 833/2014 if they are intended for DWOASOP & contract concluded after Aug 1.
Technical assistance, brokering and financial services related to the above.
Inter alia, do not process payments for the aforementioned transactions without a separate license.
Prohibited items used as components are not prevented.
Military exporters will be notified whether additional licensing is needed.
Expect a license to take about 20 days. 17
18. UK SANCTIONS FAQS
“Arctic” means north of Arctic Circle
EU has not defined “Deep Water.” UK FAQs refer readers to the US 500 foot definition.
18
The UK tends to impose lighter penalties than the United States
19. CANADIAN SANCTIONS 19
Recall the sanctions chronology comparison with the US and the EU that we used in classes 1 and 2? Next we will use this with Canada to see how it coordinates and differs from the US and EU.
20. 20
Reminder: US/EUSanctions Chronology
•
European Union
March 17 Council Decision 2014/145/CFSP & Reg. 269/2014
3/21, 4/28, 5/28- adds people
June 23 D 386 , CR 692- Cr. goods
July 29 Joint US/EU Ann’cem’t
July 30-31
Annex I to CR 428/2009 (dual use)
CR 833/2014 (finance sanctions)
Annex 2 to CR 833/2014 (shale etc)
CR 825/2014 (Crimea investment)
CR 826/2014 (more officials)
Sept 8 Decision 2014/658-9/CFSP &CR 959-961/2014, & Amendmt to CR 428/2009
Coming Soon--Guidance
United States
March 6 E.O. 13660
March 16 E.O. 13661
March 20 E.O. 13662 (SSI)
April 28 (7 officials, 17 co’s.)
May 8, 31 CFR 589
July 16 Directives 1 & 2, SSI List
July 29 Joint US/EU Ann’cem’t
Aug 13-OFAC Guidance (50%)
Sept 12 Amend Directive 1
Directives 3 and 4
General License 1(a)
Sept 17 Amend EAR 744.21
21.
March 17 Council Decision 2014/145/CFSP & Reg. 269/2014
3/21, 4/28, 5/28- adds people
June 23 D 386 , CR 692- Cr. goods
July 29 Joint US/EU Ann’cem’t
July 30-31
Annex I to CR 428/2009 (dual use)
CR 833/2014 (finance sanctions)
Annex 2 to CR 833/2014 (shale etc)
CR 825/2014 (Crimea investment)
CR 826/2014 (more officials)
Sept 8 Decision 2014/658-9/CFSP &CR 959-961/2014, & Amendmt to CR 428/2009
Coming Soon--Guidance 21
Canada Sanctions Chronology
March 17, Special Economic Measures (SOR/2014-58) – Designated Persons-Schedule 1
3/18, 3/21, 4/28, 5/4, 5/12, 6/21-adds people.
July 24 Broadens, adds financial sanctions (SOR/2014- 184) –Schedules 2 & 3
Aug 6 - adds people
Sept16 Regs amended to add names, and tighten financial restrictions 30 days + equity
Sept 29—Consolidated regulations released.
•
European Union
Canada
22. CANADIAN SANCTIONS TODAY 22
Schedule 1 (SDN Equivalent)
At least 100 individuals and entities (not including Sergei Chemezov or Sechin or Rosneft)
Schedule 2 (Financial Sanctions on Financial entities—30 days debt and equity)
Gasprombank, VEB, VTB, Bank of Moscow, Rosselkhozbank Plus Sberbank
Schedule 3 (Financial Sanctions on Energy/Military Companies)
Currently only “OAO Novatek” What’s missing? Export controls
23. CANADIAN SANCTIONS TODAY 23
http://laws.justice.gc.ca/eng/regulations/SOR- 2014-58/FullText.html
Canada grandfathers in preexisting contracts in their financial sanctions
Canadian blocking sanctions allow payments from the designated person’s funds to third parties.
Canadian sanctions are enforced by the Royal Canadian Mounted Police
Requires Canadians and people in Canada to report.
Wilful violators can be fined any amount and imprisoned up to 5 years.
Includes sanctions against assisting and promoting
Canadian Sanctions are vigorously enforced.
24. 24
SWISS « ANTI- CIRCUMVENTION » RULES
On April 2 and again on August 27 Switzerland passed measures designed to avoid circumvention of the sanctions imposed by the world community. It has also passed export controls on military and dual use goods.
But Switzerland has not recognized Russia’s annexation of Crimea and thus has effectively prohibited trade with Crimea and Sevastopol.
25. 25
April 2—individuals on EU list cannot enter into new business relations with Swiss intermediaries to transfer assets through Switzerland
List is regularly updated to match EU designated persons.
Crimea and Sevastopol Transactions
Prohibits creation of JVs and granting of loans or credit for infrastructure projects in the transport, energy or telecom industries
Especially if exploiting oil, gas or mineral resources of the area
Financial Transactions
Authorization from SECO (Swiss Secretariat for Econ Affairs) needed to undertake financial instruments with duration over 90 days with 5 Russian banks (50+% rule applies)
Authorization will be granted “if the contemplated loan does not cause the total value of the financial instruments held by the applicant to exceed the average value of that total during the preceding three years.”
Prohibits financial intermediaries from establishing new relationships with named entities.
SWISS « ANTI- CIRCUMVENTION » RULES
26. 26
Export Controls
Must notify SECO for export of certain goods to DWOASOP
Export prohibited if end user is in Crimea or Sevastopol
Military goods to Russia and Ukraine prohibited, dual use goods require a license, and licenses are only restrictively granted
Location of the Swiss ordinances
August 27 ordinance (in German): http://www.seco.admin.ch/themen/00513/00620/00622/05405/index.html?lang=de& download
April 2 ordinance: https://www.news.admin.ch/message/index.html?lang=en&msg- id=52530
Export controls: https://www.news.admin.ch/message/index.html?lang=en&msg- id=52530
Punishment for violating the rules can be fines of up to 1mil Swiss Franks and imprisonment up to 5 years.
SWISS « ANTI- CIRCUMVENTION » RULES
27. 27
Have been mirroring the E.U. sanctions
NORWEGIAN SANCTIONS
28. 28
JAPANESE SANCTIONS
http://www.mofa.go.jp/region/europe/russia/index.html
Are targeted mainly at Ukrainian related persons and companies.
April 29-visa restrictions for 23 people
July 28-
froze assets of 40 people and two entities
All goods imported to Japan directly from Crimea or Sevastopol need a license
September 25-
Japan will “tighten” exports of military and dual use tech
Five named banks will not be able to issue securities or get loans of more than 90 days without a license.
(a cumulative 50+% rule applies) The Economist posited on Sept 29 that Japanese sanctions are so mild and Japan is unlikely to impose strict sanctions on Russia due to its concern for energy security after the Fukushima disaster in 2011.
29. AUSTRALIA 29
Autonomous Sanctions Regulations of 2011
http://www.dfat.gov.au/sanctions/sanctions- regimes/ukraine.html
July 17—”SDN” list of 50 people and 11 companies
August 30-unincorparated addition 113/60???
September 1—Australia announces it “will begin to restrict
access of RF state-owned banks to capital markets
trade and investment in Eastern Ukraine & Crimea
arms and dual use goods exports;
export of goods and services for DWASOP;
sale of Australian uranium to Russia.
But!!! Nothing Yet!!!
30. AUSTRALIA 30
Sunset October 1, 2024
Negligence Standard.
In future may apply to Subsidiaries.
32. 32
Depends on the Law of the Contract of course
Is a contract entered into in violation of law automatically null and void?
If so, is a contract entered into after sanctions have gone into effect completely void, or will it be revivable after sanctions end?
Are Sanctions a Force Majeure event?
How do you need to exhaust your options before effectively claiming force majeure? Do you need to apply for a license even if there is little to no chance it will be granted?
How should you revise Force Majeure clauses to best encompass sanctions?
Do MAC clauses encompass sanction related difficulties?
What other clauses should you worry about?
Representations and Warranties?
Law of the contract?
Place of litigation or arbitration?
EFFECT ON CONTRACTS
33. Compliance? 33
Be aware of different standards of mens rea.
OFAC is prosecuting fewer but larger cases, BIS cases are more frequent.
Facilitation Problems
Referrals
Deviation from standard practices
Changing business practices to enable an otherwise sanctioned transaction is actionable.
Russian companies changing business practices before the problem arises (ie to remove decision making from a US/EU national) is not actionable.
US/EU persons must not facilitate but are not required to prevent a transaction in Russian companies they work for.
34. Compliance? 34
STEP 1—Immediate Check-accounts, assets in your control, contracts
STEP 2—Risk Assessment
STEP 3—Establish a Compliance Policy
Who, what, how
Target High Risk Areas
Include automated Screening
Include internal “sanctions”
STEP 4—Train
STEP 5—Audit & Monitor
Include reports to board
STEP 6—Regular updates
And keep a paper trail of all the above
35. Damage Control! 35
Ensure Violations are stopped immediately
Assess
How did it happen?
Rogue or systematic?
How credible is your information?
Intentional or Negligent?
Interview Witnesses
Preserve Documents
Stop all regular destruction processes!
Keep info closely held
Think about whether to voluntarily disclose to government!
36. Voluntary Disclosure 36
Can significantly mitigate damages
But what is considered voluntary disclosure?
Treatment differs with each agency/country
Failure to disclose could compound the violation.
But Assess First:
Disclosure doesn’t mean no investigation, it means you voluntarily allow an investigation.
Will disclosure uncover past transgressions?
Will attorneys’ advice need to be disclosed.
Disclosure alone isn’t enough—you may have to try to reverse the transaction(s).
Consider the international ramifications and the possible need to disclose and negotiate simultaneously with multiple countries’ authorities.