Category Archives: Export Controls and Sanctions

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New Russia, Iran, and North Korea Sanctions Become Law

Today the President signed landmark legislation into law mandating new and enhanced sanctions on Russia, Iran, and North Korea.  As noted in our prior posts, here and here, the law will tighten existing sanctions on those countries and provide the U.S. government with broader power to penalize companies under primary and secondary sanctions rules. Please … Continue Reading

OFAC Penalizes Singaporean Communications Provider $12 Million For Iranian Transactions Conducted In U.S. Dollars  

Global communications solutions provider, CSE TransTel, a subsidiary of CSE Global Limited (both based in Singapore), recently agreed to settle Iran sanctions charges leveled by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) for $12 million.  The charges involve 104 violations of the Iran sanctions between June 2012 and March 2013.  The case … Continue Reading

U.S. Blacklists the President of Venezuela as a Specially Designated National (SDN)

Today the U.S. Office of Foreign Assets Control (OFAC) took the unusual step of blacklisting the leader of a foreign country as a Specially Designated National (SDN).  OFAC added Nicolas Maduro, the President of Venezuela, to the SDN List after a flawed vote that essentially replaced the country’s democratically elected legislature with a new body … Continue Reading

Congress Passes Landmark Russia Sanctions

Last night the U.S. Senate passed sweeping sanctions on Russia, Iran, and North Korea by a vote of 98-2.  The Countering America’s Adversaries Through Sanctions Act (the Act) contains important changes to U.S. sectoral sanctions on Russia and provides enhanced authority to issue primary and secondary sanctions on that country. The bill looks likely to … Continue Reading

Siemens Cracks Down on Russian Sanctions Evasion

Siemens, a German corporation, has announced that it will no longer deliver power plant equipment to state-controlled firms in Russia after it claimed to discover that Siemens’ Russian customer, Technopromexport, had diverted gas power plant turbines to the disputed territory of Crimea. The United States and the European Union have implemented sanctions targeting Crimea since … Continue Reading

President Punts on Sudan Sanctions

The President issued a new Executive Order today delaying a decision on whether to permanently lift sanctions on Sudan. In January, President Obama announced the interim lifting of U.S. sanctions on Sudan.  At that time the Office of Foreign Assets Control (OFAC), the agency primarily responsible for implementing U.S. sanctions, issued a general license (or … Continue Reading

US Govt Seeks $1.9 Million In North Korea Sanctions and Money Laundering Case

A recent suit filed by the U.S. Department of Justice (DOJ) for the forfeiture of nearly $2 million highlights the broad extraterritorial reach of U.S. sanctions laws.  On June 14, DOJ filed a complaint to seize funds associated with transactions between several Chinese companies, including Mingzheng International Trading Limited (Mingzheng).  Mingzheng and the other companies … Continue Reading

California Court Orders TransUnion to Pay Record $60M for FCRA Violations for Erroneously Linking Consumers to Criminals in OFAC Database

A California jury in federal court ruled on Tuesday, June 20, that TransUnion violated the Fair Credit Reporting Act (FCRA) by erroneously linking certain consumers with similarly named terrorists and criminals in the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC’s) database.  The jury awarded statutory and punitive damages in excess of $60 million, … Continue Reading

BIS Alert! New Encryption Controls Guidance Posted

The Commerce Department’s Bureau of Industry and Security (BIS) has posted long-awaited updates to its guidance regarding changes to a number of encryption-related provisions in the Export Administration Regulations (“EAR”). The updates cover the changes to encryption controls adopted in September 2016 and include a quick reference guide and updated flow charts for classifying encryption items, … Continue Reading

Congress Takes The Lead In Broad New Sanctions Against Russia

On June 15, 2017, the Senate overwhelmingly – by a vote of 98-2 – approved broad new sanctions against Russia in response to that country’s interference in the 2016 U.S. election and its ongoing aggression in Syria and Ukraine. The legislation would make several big changes.  First, the package would codify existing sanctions on Russia, … Continue Reading

Appeals Court Says That Actual Arrival In Iran Is Not Necessary For OFAC To Find Violation

On May 26, the U.S. Court of Appeals for the DC Circuit remanded for further consideration OFAC’s imposition of a $4 million penalty against Epsilon Electronics for 39 shipments found to violate the Iranian Transactions and Sanctions Regulations (“ITSR”).  According to the DC Circuit, OFAC failed to meet its burden to justify its finding of … Continue Reading

Trump Administration Nominates Richard Ashooh as Dept of Commerce, Bureau of Industry and Security (BIS) Assistant Secretary

Richard Ashooh was nominated by the White House on May 25 as Department of Commerce, Bureau of Industry and Security (BIS) Assistant Secretary.  This key position plays an important role in a wide variety of interagency export control policy matters, including the continuing review of control categories and export reform, as well as deciding critical … Continue Reading

Surge of Commerce Export Enforcement Personnel Starting in October 2018

As part of the Trump Administration’s increase in export and sanctions enforcement, the Commerce Department’s Bureau of Industry and Security plans to add 19 new enforcement personnel in their 11 regional offices during the government’s new fiscal year, which starts October 2018.  This will lead to more announced and unannounced site visits to manufacturing and … Continue Reading

U.S. Lawmakers Move to End Cuba Travel and Export Restrictions

On May 25th, U.S. Senators introduced the “Freedom for Americans to Travel to Cuba Act of 2017” (S. 1287).  The bill is sponsored by 54 senators and it would eliminate restrictions on travel to Cuba by American citizens and legal residents, and associated travel related banking restrictions.  Fourteen sponsors introduced a “Freedom to Export to … Continue Reading
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