U.S. State Department Targets Russian, Iranian Firms in Sanctions Move Against WMD and Missile Proliferation

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The U.S. Department of State imposed sanctions on September 2, 2015, against 23 companies around the world for involvement in the transfer or purchase to or from Iran, North Korea or Syria of goods, services or technology listed on multilateral export or U.S. national control lists or other items that could make a material contribution to the development of weapons of mass destruction or missile proliferation. Sanctions have been enacted against these companies under Section 3 of the Iran, North Korea, and Syria Nonproliferation Act. The sanctions include broad prohibitions on the export of controlled items to penalized companies and the denial of access for those companies to U.S. government procurement, assistance or defense articles or services.

From the State Department notice -

The Act provides for penalties on foreign entities and individuals for the transfer to or acquisition from Iran since January 1, 1999; the transfer to or acquisition from Syria since January 1, 2005; or the transfer to or acquisition from North Korea since January 1, 2006, of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the potential to make a material contribution to the development of weapons of mass destruction (WMD) or cruise or ballistic missile systems. The latter category includes (a) items of the same kind as those on multilateral lists but falling below the control list parameters when it is determined that such items have the potential of making a material contribution to WMD or cruise or ballistic missile systems, (b) items on U.S. national control lists for WMD/missile reasons that are not on multilateral lists, and (c) other items with the potential of making such a material contribution when added through case-by-case decisions.

Please see full advisory for more information.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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