Professional Biography:
Jeffrey Richardson advises multinational clients in the information technology and defense sectors on matters including mergers and acquisitions, distribution agreements, joint ventures, and strategic corporate structuring.
Specifically, Jeffrey brings expertise in matching operational business execution requirements with functional business structures. He is frequently engaged in advising clients of export control compliance, as well as the impact of intellectual property matters within business structures. His breadth of experience is informed by a business management and litigation background.
Export Control Compliance
Jeffrey is a member of Miller Canfield s Export Control Practice Group, focusing on client matters arising under ITAR, OFAC, EAR, as well as other export control regulations. This process includes the implementation of export control compliance programs, license applications, controlled asset identification, in addition to seeking appr
Key Points
On December 14, 2020, in response to Turkey’s procurement of the S-400 surface-to-air missile system from Russia in 2019, the Trump administration imposed new sanctions on the Turkish Presidency of Defense Industries (SSB) and four of its officers pursuant to the CAATSA sanctions provisions enacted by Congress against Russia in 2017. This follows Congressional approval of the NDAA for Fiscal Year 2021 by a veto-proof majority on December 11, 2020, which includes specific provisions to compel the imposition of the new sanctions measures.
The European Union separately has also recently adopted new sanctions against Turkey in connection with disputed Turkish drilling activities in the Eastern Mediterranean.
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The U.S. Department of State (“State Department”) announced the imposition of sanctions on Turkey’s Presidency of Defense Industries (“SSB”) pursuant to Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”). The U.S. is sanctioning SSB over its procurement of the S-400 surface-to-air missile system from Russia’s Rosoboronexport (“ROE”). SSB is Turkey’s primary defense procurement entity and ROE is Russia’s main exporter of arms. As a result of Turkey’s actions, the U.S. is imposing full blocking sanctions on four SSB officials along with certain non-blocking CAATSA sanctions on the SSB entity.
United States Rescinds Designation of Sudan as State Sponsor of Terrorism
Key Points
On December 14, 2020, the U.S. Department of State officially rescinded Sudan’s designation as an SST in light of Sudan’s actions to normalize relations with Israel and resolution of terrorism claims.
This action paves the way for the lifting of mandatory U.S. trade restrictions on business involving Sudan, the government of Sudan and Sudanese nationals that was based on Sudan’s previous SST listing.
Before embarking on any activity or transaction involving Sudan, companies should be diligent to assess the extent to which remaining federal and state restrictions, including state level divestment sanctions regarding Sudan, as well as contractual or other relevant restrictions regarding Sudan still in place, may affect new business opportunities.
December 18, 2020
On December 14, 2020, the United States imposed sanctions on the Republic of Turkey’s Presidency of Defense Industries (“SSB”), the country’s defense procurement agency, and four senior officials at the agency, for knowingly engaging in a “significant transaction” with Rosoboronexport (“ROE”), Russia’s main arms export entity, in procuring the S-400 surface-to-air missile system. These measures were a long-time coming under Section 231 of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) of 2017, the President has been
required to impose sanctions on any person determined to have knowingly “engage[d] in a significant transaction with a person that is part of, or operates for or on behalf of, the defense or intelligence sectors of the Government of the Russian Federation.” This includes ROE, and Turkey’s multi-billion dollar S-400 transaction with ROE has been public knowledge for at least three years. Indeed, in