THE JOURNAL OF EXPORT CONTROLS AND SANCTIONS

Issue 79, May 2019

Can but can’t! On the short payment windows available in credit-based sanctions

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By Tim Stephenson,  M Taher & Co www.mtaher.com   With the US 8 May 2018 JCPOA withdrawal and its aftermath still very much to the fore, and increased pressure on Iranian interests a regular theme, it is worth issuing a reminder about another sanctions theatre which has existed, comparatively quietly and sometimes almost inertly, for over five years. Such is the credit-based sectoral structure, which is mainly Russia-targeted and Ukraine in geopolitical origin. Amid what is usually outright proscription, these provisions are hybrid in that they do not forbid trade with the bodies listed on the Sectoral Sanctions Identifications (‘SSI’)...

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