Enforcement

OFAC announced a $7,452,501 settlement with State Street Bank and Trust Company on behalf of itself and its subsidiary, Charles River Systems, Inc.  State Street agreed to settle its potential civil liability for 38 apparent violations of OFAC's Ukraine-/Russia-Related sanctions. The apparent violations involved invoices that were redated or reissued by Charles River between 2016 and 2020 for certain customers who were subject to Directive 1 of Executive Order 13662, as well as certain payments outside of the applicable debt tenor (maturity range) accepted by Charles River from these customers.

A Florida man was charged  with conspiring and acting as an agent of the PRC without notification to the Attorney General. If convicted, he faces a maximum penalty of 15 years in prison.  From as early as 2012, Peng Li, 59 allegedly served as a cooperative contact working at the direction of officers of the Ministry of State Security to obtain information of interest to the PRC government.

A grand jury in Kansas City, Kansas, returned an indictment on Wednesday charging a fugitive North Korean national for his involvement in a conspiracy to hack and extort U.S. hospitals and other health care providers, launder the ransom proceeds, and then use these proceeds to fund additional computer intrusions into defense, technology, and government entities worldwide. Rim Jong Hyok worked for North Korea’s Reconnaissance General Bureau (RGB), a military intelligence agency, and participated in the conspiracy to target and hack computer networks of U.S. hospitals and other health care providers, encrypt their electronic files, extort a ransom payment from them, launder those payments, and use the laundered proceeds to hack targets of interest to the North Korean regime.

An Illinois woman was sentenced to 24 months in federal prison for conspiring to unlawfully export to Russia defense articles – including thermal imaging riflescopes and night-vision goggles – without a license in violation of the Arms Export Control Act. To conceal her unlawful activities, when Shifrin exported the defense articles to Russia, she listed fictitious sender names and addresses on the packages containing the defense articles, falsely identified the items in the packages as non-export-controlled items such as clothing, and concealed the defense articles in other items such as toolkits and kitchen appliances.

Iranian national Saeid Haji Agha Mousaei, 53, made his initial appearance yesterday in Chicago federal court following his extradition from the United Kingdom to face charges for his role in a years-long conspiracy to evade U.S. export restrictions and transship advanced U.S. electronic testing technology to Iran using third-party countries. Mousaei and his co-defendants understood export restrictions on U.S.-origin goods to prohibited destinations like Iran and falsely represented to U.S. distributors that their purchases would remain in countries other than Iran, like the United Arab Emirates (UAE) or Armenia, where the defendants controlled unnamed companies. In reality, after arranging for distributors of U.S.-origin goods to export shipments to the UAE, the defendants allegedly transshipped goods from the UAE to Iran without the required license and in violation of U.S. law.

Alabama man Ray Hunt , pleaded guilty to conspiracy to export U.S.-origin goods to the Islamic Republic of Iran in violation of trade sanctions. Hunt, a naturalized US Citizen also known as Abdolrahman Hantoosh, is alleged to have conspired to export U.S.-origin parts used in the oil and gas industry, including control valves and oil tubing, through his Alabama-based company, Vega Tools LLC, to customers in Iran. The scheme transshipped the goods to Iran through Turkey and the UAE to evade U.S. sanctions.

A Russian national based in Hong Kong pleaded guilty to money laundering and smuggling charges for illicitly procuring dual-use, military-grade microelectronics for export to Russia, Members of the conspiracy procured these sensitive microelectronics by falsely representing to the U.S. distributors (who, in turn, are required to report to U.S. agencies) that the Hong Kong shell entity was sending the shipments to end users located in China, Hong Kong, and other countries outside of Russia for use in electron microscopes for medical research. In reality, the OLED micro-displays were destined for end users in Russia.

Two men pleaded guilty July 9 to conspiracy to commit export control violations for their roles in a global procurement scheme on behalf of sanctioned Russian companies, including Russian military companies.   Some of the electronic components shipped by the defendants were later found in seized Russian weapons platforms and signals intelligence equipment in Ukraine. Salimdzhon Nasriddinov, 53, a Brooklyn resident and dual citizen of Russia and Tajikistan, was arrested on Oct. 31 in Brooklyn.    Nikolay Goltsev, 38, of Montreal and an associate who pleaded guilty  in February were arrested at a hotel in Manhattan on Oct. 31 during a trip to New York to visit Nasriddinov.

Following on the June 18 Indictments of the Los Angeles money launderer for the Mecican drug traffickers, Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a Mexico-based money launderer and China-based members of a money laundering organization with criminal links to the Sinaloa Cartel.. The United States is working with Chinese authorities to target illicit financing networks, including those linked to the fentanyl trade. Chinese Money Laundering Organizations are now one of the key actors laundering money professionally in the United States and worldwide, and are rapidly becoming one of the most prominent money laundering threat actors facing the U.S. financial system.

Two people were arrested Tuesday morning for shipping controlled avionics from New Jersey to the United Arab Emirates without having obtained the required license and authorization. The defendants obtained an ADIRU, a component that supplies air data and inertial reference information to pilots’ electronic flight instrument system displays and attempted to ship it to another company in the UAE.

A Florida man has been indicted for attempting to export scientific equipment from the United States into Russia without a license. Kirill Gordei, 34, a citizen of Belarus and permanent resident of the U,S, allegedly falsely claimed that he was shipping a Thermo Fisher Scientific Orbitrap Exploris GC 240 Mass Spectrometer  to Uzbekistan when it was, in fact, destined for Russia.

The Department of Commerce’s Bureau of Industry and Security (BIS) Export Enforcement published an updated version of Don’t Let This Happen to You!, a compendium of case examples highlighting BIS criminal and administrative enforcement efforts. The publication was last updated in March 2024.

PetroChina International America Inc. (PCIA) has entered into an agreement to pay a fine and monetary forfeiture totaling $14.5 million for violations of U.S. export law, including cargos misclassified and/or undervalued at the time of export and then entered into AES.

Treasury's Office of Foreign Assets Control (OFAC) today announced a $538,000 settlement with Mondo TV, S.p.a. an Italian animation company for 18 apparent violations of the North Korea Sanctions Regulations. Between May 2019 and November 2021, Mondo remitted approximately $537,939 to a Government of North Korea-owned studio in payment for outsourced animation work. In doing so, Mondo caused U.S. financial institutions to process wire transfers that contained the blocked property interests of the Government of North Korea and to export financial services to North Korea.

Unlicensed exports of fruit flies genetically modified to produce a subunit of a controlled toxin drew Indiana University a  penalty from the  Commerce Department.   As part of a settlement agreement, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an order imposing an administrative penalty on Indiana University (IU) related to exports by IU’s Bloomington Drosophila Stock Center (BDSC).  

A Washington State importer firm pleaded guilty to one felony count, was fined and received probation for evading source of origin declarations for Chinese-origin cabinets in violation of the Lacey Act. Tip the Scale LLC, of Tacoma, Washington, pleaded guilty and was sentenced for making false declarations regarding the species and harvest location of timber used in wooden cabinets and vanities.  The firm agreed to appoint its current Sales Manger, Tran Dip as Chief Compliance Officer to implement a compliance plan.  

A Canadian national and resident of the People’s Republic of China (PRC), pleaded guilty today to conspiring to send trade secrets that belonged to Tesla Motors. …

The Department of Commerce’s Bureau of Industry and Security (BIS) has imposed a three-year denial order against a Portland, Oregon, package forwarding service prohibiting the firm from from participating in all exports under BIS jurisdiction from the United States. “If a forwarding company – with an entire business model based on exports – fails to implement an adequate compliance program even while subject to a suspended denial order, it should not be able to export items subject to the EAR from the United States,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod.

Coordinator on Global Anti-Corruption Richard Nephew will travel to Montenegro, Lithuania, and Albania June 16-21. Mr. Nephew will visit Podgorica, Montenegro to meet with government officials and civil society representatives. He will then travel to Vilnius, Lithuania on June 18-19, to the opening plenary of the International Anti-Corruption Conference.

A Turkish aviation operator was fined for ferrying passengers into and out of Russia on a US manufactured Gulfstream executive jet without the requisite export license.   The Commerce Department (BIS)  imposed a civil penalty of $285,000 against Sapphire Havacilik San Ltd. STI (Sapphire), an aviation company headquartered in Ankara, Türkiye, to resolve violations of the Export Control Reform Act of 2018 (ECRA). Although the Russian national passengers provided payment to Sapphire through third-party non-Russian charter brokers, such flights into Russia—which were arranged for the benefit of the Russian national or nationals on board—were nevertheless controlled by or under charter or lease by a Russian national.  As such, the relevant flights did not fall within license exception Aircraft, Vessels, and Spacecraft (AVS) and violated Section 764.2(a) of the ECRA.

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