Action Item: With less than 30 days remaining before the July 1, 2016, effective date of the new International Convention for the Safety of Life at Sea (“SOLAS”) Regulation VI/2 amendments, the International Maritime Organization (“IMO”), Administrations, and industry continue to tackle unanswered compliance questions and concerns.
Action Item: The recently published Well Control Rule will require significant changes to Blow-Out Preventer (“BOP”) systems and well operations. Stakeholders in offshore oil and gas operations should carefully evaluate the new measures, review safety procedures, and develop plans to come into compliance within the time frames mandated by the regulations.Continue reading “The Well Control Final Rule Is Here, Finally”
Action Item: The National Marine Fisheries Services (“NMFS”) promulgated a final rule identifying critical habitats for the endangered Northern Atlantic Right Whale. Stakeholders involved in spill response, ocean and offshore energy (including renewable energy), fisheries, and other activities requiring federal permits or permission should examine the final rule to determine current possible impacts to activities in the Atlantic Ocean. Additionally, stakeholders involved in industries in the Atlantic Ocean, particularly in the South Atlantic, should consider engaging early with NMFS to minimize permitting delays and costly modifications to plans.Continue reading “Critical Habitat for Right Whales Expanded”
Action Item: January 16, 2016, marked Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), an agreement between Iran and the EU3+3 nations (the United Kingdom, France, Germany, Russia, China, and the United States) to ease international trade sanctions in exchange for constraints on Iran’s nuclear capabilities. As of January 16, the United States lifted a number of nuclear-related sanctions on Iran, particularly the so-called “secondary sanctions” related to non-U.S. persons. With limited exceptions, U.S. persons and companies continue to be broadly prohibited from engaging in transactions with Iran, but a limited exception has been implemented to permit foreign subsidiaries of U.S. entities to do business with Iran in some circumstances.Continue reading “January 16th Marked Changes in U.S. Sanctions on Iran”