Archives: Export Controls & Sanctions

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Chinese National Enters Guilty Plea for Violating US Export Controls

On 21 April 2017, the US Department of Justice announced that Fuyi Sun pled guilty to violating the International Emergency Economic Powers Act, the law underlying US export controls. Specifically, Sun admitted to attempting to export to China high-grade carbon fiber – an item with aerospace and defense applications – without the required license.… Continue Reading

BIS Modifies Entity List Designation

Effective 18 April 2017, the US Commerce Department, Bureau of Industry and Security (BIS) has revised the Entity List entry for Russia’s Federal Security Service (Federalnaya Sluzhba Bezopasnosti or FSB) to conform to the OFAC general license adopted on 2 February 2017, General License No. 1. That general license authorises transactions otherwise prohibited under Executive … Continue Reading

OFAC Declines to Issue Waivers for Prohibited Russian Oil Operations

In a single sentence press release published to the OFAC website on 21 April 2017, Treasury Secretary Steven T. Mnuchin announced that OFAC “will not be issuing waivers to U.S. companies, including Exxon, authorizing drilling prohibited by current Russian sanctions”. The announcement reinforces current US sanctions against Russia, which generally prohibit US persons from providing goods, … Continue Reading

OFAC Sanctions Staff of the Syrian Scientific Studies and Research Center

On 24 April 2017, the US Treasury Department’s Office of Foreign Assets Control (OFAC) designated 271 persons working in the Syrian Scientific Studies and Research Center to be added to the agency’s Specially Designated Nationals (SDN) and Blocked Persons List. In its press release announcing the action, OFAC attributed the Syrian Scientific Studies and Research … Continue Reading

UK SFO Opens Probe into KBR, Inc.

Due to the UK Serious Fraud Office’s (SFO) ongoing investigation into Unaoil, in a press release dated 28 April 2017, the SFO confirms, “it has opened an investigation into the activities of KBR, Inc’s United Kingdom subsidiaries, their officers, employees and agents for suspected offences of bribery and corruption”. KBR, Inc. is a US based … Continue Reading

UK Scheduled to Publish Bill on Post-Brexit Sanctions Collaboration With the EU

In a parliamentary debate on Eastern Ukraine, UK Foreign Secretary Boris Johnson announced that the UK will be introducing a bill “on how we will continue to take part in sanctions jointly with our friends and partners across the channel”. Boris Johnson also stated that the UK “already leads the way in imposing sanctions on … Continue Reading

UK Export Control Organisation (ECO) Revokes Six Open General Export Licences (OGELs)

On 5 April 2017, the ECO revoked the following OGELs, including: Exports of military goods, software and technology (new OGEL for Military Goods, Software and Technology) Exports under the US-UK Defence Trade Co-operation treaty (new OGEL for Exports under the US-UK Defence Trade Cooperation Treaty) Exports of military goods, software or technology to a government … Continue Reading

UK Office of Financial Sanctions Implementation (OFSI) Publishes New Guidance on the New UK Financial Sanctions Regime

Following the coming into force of Part 8 of the Policing and Crime Act 2017, which introduces new monetary penalties for breaches of financial sanctions, OFSI has published guidance on the new regime, including: Guidance on monetary penalties for breaches of financial sanctions A response to OFSI’s consultation on the process for imposing monetary penalties … Continue Reading

UK Government Launches Public Consultation on the Future Legal Framework for Imposing and Implementation Sanctions Post-Brexit

On 21 April, the UK government launched a public consultation on its proposals for domestic sanctions legislation. The consultation sets out the UK government’s thinking on the overarching legal powers the UK will need to impose its own domestic sanctions once the UK leaves the EU. The consultation is scheduled to run for nine weeks … Continue Reading

European Commission Updates Combined Nomenclature and Dual-Use Classification Correlation Table

The EU Commission has updated the Combined Nomenclature (CN) and Dual-Use (DU) Correlation table. The revision contains changes to the EU Dual-Use export control list, which came into force in November 2016 in line with the decision taken within the framework of the international non-proliferation regimes and export control arrangements back in 2015. The update … Continue Reading

CFIUS Filing Update: Sonaca S.A. and LMI Aerospace

Status:  Review   Acquirer:  Sonaca S.A. (Belgium) Acquired:  LMI Aerospace, Inc. (US) Value:  US$14/Share (total value unknown) Industry:  Aerospace   UPDATE:  In relation to the February 16, 2017 Agreement and Plan of Merger between LMI Aerospace, Inc., a Missouri corporation, and Sonaca S.A., a Belgian limited liability company, the parties have announced that:  “On March … Continue Reading

Congress Introduces North Korea and Iran Sanctions Legislation

House lawmakers introduced a new bill, the Korean Interdiction and Modernization of Sanctions Act (H.R. 1644), that would expand existing sanctions targeting trade with the North Korean regime. Further, two new Iran sanctions bills were introduced in the House and Senate – the Iran Ballistic Missiles and International Sanctions Enforcement Act (H.R. 1698) and the … Continue Reading

OFAC Issues General License Authorising Certain Transactions with Soho Panama, S.A.

On 9 March 2017, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 4F, authorising limited transactions with the Panamanian Mall, Soho Panama, S.A, and related entity Westline Enterprises, Inc. Soho Mall Panama was designated for sanctions under the Foreign Narcotics Kingpin Designation Act (21 U.S.C. 1901-1908) in May 2016, in … Continue Reading

BIS Removes ZTE Corp. From Entity List

The US Department of State’s Bureau of Industry and Security (BIS) has removed from the Entity List China’s telecommunications equipment firms Zhongxing Telecommunications Equipment Corporation and ZTE Kangxun Telecommunications Ltd., known collectively as ZTE. The action follows the agency’s recently announced, record-breaking settlement for US export controls violations, according to which those entities agreed to … Continue Reading

UK Introduces New Monetary and Criminal Penalties for Breach of Financial Sanctions

The new Policing and Crime Act 2017 (the Act), which comes into force in April 2017, provides HM Treasury with enforcement powers to punish breaches of financial sanctions. Under the Policing and Crime Act 2017, HM Treasury has the power to impose monetary penalties if it is satisfied that a person acted in breach of … Continue Reading

BIS Announces Arrest of Ukrainian National and a US$27 Million Settlement With Access USA Shipping, LLC

On 7 March, the Bureau of Industry and Security (BIS) announced the arrest of a Ukrainian national on charges related to the export of military technology to Ukraine. Separately, on 24 March, the BIS announced a US$27 million civil settlement with Access USA Shipping, LLC, a company based in Sarasota, Florida, for alleged export controls violations … Continue Reading

ZTE Corporation Enters Into US$1.19 Billion Settlement

On 7 March, the Departments of Commerce, Justice, and Treasury jointly announced a US$1.19 billion settlement with China-based telecommunications company ZTE Corporation and its subsidiaries and affiliates (together ZTE) for allegedly violating US sanctions and export controls laws. ZTE agreed pay a US$100.9 million civil penalty to the Office of Foreign Assets Control (OFAC); a … Continue Reading

UK Export Control Organisation (ECO) Updates Six Open Licences

The ECO has announced that it has updated and amended six open general export licences (OGELs) in order to reflect the amendments to the Export Control Order 2008, which came into force on 22 February, and the replacement of Schedule 1 to the OGEL for printed circuit boards (PCB) and components for military goods. The … Continue Reading

UK Export Control Organisation (ECO) Amends Its Rules on Capital Punishment Goods

In a notice to exporters from 15 March, the ECO announced that it amended its rules concerning the export of goods which could be used for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, implementing the EU’s new export control rules from November 2016. The list of these goods can be … Continue Reading

UK Export Control Organisation (ECO) Withdraws Iran End-User Concern List

In a notice to exporters from 22 March, the ECO announced that its Iran list has been withdrawn, owing to the substantial lifting of EU sanctions on Iran under the JCPOA nuclear deal signed in 2015. The list was designed to provide information relating to certain entities, companies and organization in Iran for exporters concerned … Continue Reading