Export Controls & Sanctions

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The Real Significance of OFAC’s Sanctions Compliance Guidance | Sanctions Webinar on May 16, 2019

On May 2, 2019, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) released guidance on effective sanctions compliance programs. While this is the first document of this kind from OFAC, similar guidance documents by the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have been on the books … Continue Reading

Deadline Approaches for Certain Transitioning USML Category Items to CCL

Due to the Export Control Reform (ECR) that began nearly six years ago, the Department of States’s Directorate of Defense Trade Controls (DDTC) has updated 18 of the 21 categories in the United States Munitions List (USML), and most of these categories had items transition to the Commerce Control List (CCL) of the Export Administration Regulations (EAR) by respective … Continue Reading

DDTC Fines Alleged Violations of ITAR and Failure to Appoint Qualified Empowered Offcial

On February 28, 2019, with a civil penalty of US$400,000, Darling Industries, Inc. of Tucson, Arizona settled allegations for violating six counts of the Arms Export Control Act (AECA), as well as the International Traffic in Arms Regulations (ITAR), in connection with unauthorized exports of defense articles, provisions of defense services and failure to appoint a qualified Empowered Official.… Continue Reading

OFAC Reaches Settlement Agreement With e.l.f. Cosmetics, Inc.

On January 31, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has reached a settlement agreement with e.l.f. Cosmetics, Inc. in the amount of US$996,080 for potential civil liability relating to 156 apparent violations of North Korea Sanctions Regulations. The potential violations stem from importation of false eyelash kits from the People’s Republic of … Continue Reading

OFAC Issues New Venezuela-related Executive Order and General Licenses

On January 28, 2019, the Department of Treasury’s Office of Foreign Assets Control (OFAC) announced that it has designated Petroleos de Venezuela, S.A. (PdVSA) following Executive Order (E.O.) 13850, after a determination by Treasury Secretary Steven T. Mnuchin and Secretary of State Michael Pompeo that PdVSA was operating in the Venezuelan oil sector. Additionally, OFAC has amended General License 3 and … Continue Reading

OFAC Issues Venezuela-related General License 6

On January 8, 2019, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Venezuela-related General License 6, which authorizes the winding down of certain specified transactions with Globovision Tele C.A. and Globovision Tele CA, Corp. until January 8, 2020. Additionally, OFAC issued new FAQs for General License 6, and also added several new individuals and entities to … Continue Reading

BIS Announces Former Florida CEO Pleads Guilty to Export Violations

On December 14, 2018, the Bureau of Industry and Security (BIS) announced that Eric Baird, former Chief Executive Officer for a Florida based package consolidation and shipping service, pleaded guilty to a single count of felony smuggling and 166 violations of US export control laws. On December 12, 2018, BIS imposed civil penalties of US$17 million and a five-year denial … Continue Reading

Commerce Extends Deadline for Public Comments to Export Controls on Emerging Technologies to January 2019

UPDATE:  BIS is extending the public comments deadline on emerging technology export controls from December 19 this year to January 10, 2019, per an unpublished Federal Register notice released on December 13. The proposed rule will officially appear in the Federal Register on December 14. Posted on November 26, 2018 On November 19, 2018, the US … Continue Reading

EU Introduces New Sanctions Regime Against Persons Involved in Proliferation and Use of Chemical Weapons

On October 15, 2018, the Council of the EU adopted new sanctions against people and entities involved in providing financial, technical or material support for or otherwise involved in any business transaction related to proliferation of chemical weapons. In particular, EU sanctions provide for the freezing of assets for sanctioned people/entities.… Continue Reading

EU Updates Its List of Sanctioned Entities

In October 2018, the EU decided to amend its list of sanctioned entities and persons in the following countries: Burundi, Guinea and North Korea. Further, the European Commission added new persons to sanctions directed against the ISIL (Da’esh) and Al-Qaida organizations, and removed restrictions imposed on one Iraqi entity. The up-to-date consolidated list of all entities and people subject to EU … Continue Reading

OFAC Issues Belarus General License 2F

On October 24, 2018, Office of Foreign Assets Control (OFAC) announced that, together with the Department of State, it is extending the Belarus General License 2F’s expiration date. The general license authorizes transactions with certain entities in Belarus pursuant to Executive Order 13405. However, the general license does not authorize the release of blocked property. The expiration date for the general … Continue Reading

BIS Amends the EAR to Implement 2017 Wassenaar Plenary Agreements

The US Department of Commerce, Bureau of Industry and Security (BIS) has amended the Export Administration Regulations (EAR) to reflect the 2017 changes to the dual-use controls adopted during the 2017 Wassenaar Arrangement Plenary Meetings. As set forth in the October 24, 2018 announcement in the Federal Register, the amendments revise 50 Export Control Classification Numbers (ECCNs) throughout the Commerce Control … Continue Reading

OFAC Temporarily Extends Ukraine-related General Licenses

On October 12 and October 19, 2018, Office of Foreign Assets Control (OFAC) extended the expiration date of certain Ukraine-related General Licenses. Specifically, OFAC issued General License 13E and 13F, Authorizing Certain Transactions Necessary to Divest or Transfer Debt, Equity, or Other Holdings in Certain Blocked Persons, which extend the deadline for certain transactions with GAZ Group and with  RUSAL … Continue Reading

Department of the Treasury Issues Iran-related Designations

On October 16, 2018, OFAC announced sanctions “against a vast network of businesses providing financial support to the Basij Resistance Force (Basij), a parliamentary force subordinate to Iran’s Revolutionary Guard Corps (IRGC).” According to OFAC, the Basij militia recruits, trains and deploys child soldiers to fight in IRGC conflicts across the region. Bonyad Taavon Basij, an Iran-based network, is comprised of … Continue Reading
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