Sanctions

After deftly avoiding the sanctions levied in the past on US Defense contractors by Beijing for their transactions with Taipei,  Boeing’s Defense, Space & Security unit has been placed on the Ministry of Commerce's “unreliable entities list" (UEL). In April MofCom sanctioned dronemaker General Atomics and General Dynamics Land Systems, while the announcement omitted Boeing, the maker of Taipei's Harpoon anti-ship misssile system.  The May 20 announcement reiterates the April actions, adding Boeing.

The termination of general license 44A, which had offered temporary relief from Venezuel oil sanctions, reportedly has created a crush of license applications to OFAC.

In response to Ankara's suspension of trade with Israel,The US Department of Commerce's Bureau of Industry and Security (BIS) has issued an antiboycott advisory on Turkey. U.S. companies operating in Türkiye, in particular, are cautioned to be alert to their receipt of any requests to refrain from importing or exporting goods to or from Israel or to provide certification that the goods are not of Israeli origin or do not contain Israeli-origin components or materials. 

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Ali Yagoub Gibril and Osman Mohamed Hamid Mohamed, pursuant to Executive Order (E.O.) 14098, for leading the Rapid Support Forces’ (RSF) war campaign. The RSF’s attacks in North Darfur, which started last month, have caused dozens of civilian casualties, including children.

Treasury’s Office of Foreign Assets Control (OFAC) is imposing sanctions on two Russian individuals and three Russia-based entities for facilitating weapons transfers between Russia and the Democratic People’s Republic of Korea (DPRK).

Treasury is imposing sanctions on three Nicaragua-based entities, the Training Center of the Russian Ministry of Internal Affairs in Managua (RTC); Compania Minera Internacional, S.A. (COMINTSA); and Capital Mining Investment Nicaragua, S.A. The RTC is a Nicaragua-based subdivision of the Government of the Russian Federation’s (GOR) Ministry of Internal Affairs, and is a "key actor in the Nicaraguan regime’s repression of civil society and unjust detention and imprisonment of individuals for expressing dissent, or otherwise peacefully exercising their human rights and fundamental freedoms," according to the OFAC statement. The designations of COMINTSA and Capital Mining target government-affiliated gold companies generating revenue for the Ortega-Murillo regime. Gold is Nicaragua’s top commodity export.

Treasury’s Office of Foreign Assets Control (OFAC) designated one Russian individual and three Russia-based companies involved in an attempted sanctions evasion scheme in which an "opaque and complex supposed divestment" could have unfrozen more than $1.5 billion worth of shares belonging to U.S.-designated Russian oligarch Oleg Deripaska. The transactions was part of a scheme to repatriate some of Austria's  Raiffeisen Bank capital stranded in Russia.

The Commerce Department’s Bureau of Industry and Security added 37 entities – mostly based in China – to the Entity List under the Export Administration Regulations.  BIS said the action, announced Thursday, reflects the Administration’s commitment to safeguarding US national security and foreign policy interests.

Etablissements Maurel & Prom S.A. (Paris:MAU) (“M&P”, “the Group”) announces it has received a specific license it had applied for on 1 September 2023 from the U.S. …

On Wednesday 8 May 2024, the UK government hosted a senior US government delegation for the second US-UK Strategic Sanctions Dialogue. The United States and the United Kingdom reaffirmed that sanctions and export controls are essential tools of national security policy. The delegations discussed the uses of targeted, coordinated sanctions and export control measures to deter and disrupt malign activity and to defend international norms.

OFAC has extended the General License 8M issued last November through November 2024. The GL authorizes certain disbursements necessary for the maintenance and security of operations, but not the drilling, lifting or transportation of petroleum for PDVSA, the Venezuelan state-owned oil company.

OFAC announced it has removed Russo-Maltese executive jet operator Emperor Aviation and its fleet from the list of Specially Designated Nationals.   No explanation was provided for the change. The company and aircraft had been added to OFAC’s Specially Designated Nationals (SDN) list for conducting travel for the family of Suleiman Kerimov.

OFAC has deployed its new Sanctions List Service (SLS).  SLS is now the primary application OFAC will use to deliver sanctions list files and data to the public. OFAC's Sanctions List …

On April 17, 2024, the Enforce and Protect Act (EAPA)’s Final Rule takes effect. EAPA establishes procedures for an “ interested party” to submit an allegation that an importer is evading its payment of antidumping and countervailing (AD/CVD) duties.  

May 1 the Treasury Department issued sanctions targeting Russia’s military-industrial base and chemical and biological weapons programs,  as well as companies and individuals in third countries that help Russia acquire key inputs for weapons or defense-related production. The action includes nearly 60 targets located in Azerbaijan, Belgium, the PRC, Russia, Slovakia, Türkiye, and the United Arab Emirates (UAE).  

On 1 May, the U.K. Office of Financial Sanctions Implementation (OFSI) introduced Frequently Asked Questions (FAQs), a new form of additional guidance aimed at providing technical support to industry partners and the public. 

Included among the munitions and TikTok drama, the foreign aid package signed last week has material changes for the sanctions compliance practitioner. Front and center for sanctions practitioners is the extension of the statute of limitations for sanctions (SOL) violations.

Treasury’s Office of Foreign Assets Control is sanctioning over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale …

Tuesday the Treasury Department announced sanctions on Iranian cyber actors and representatives of Islamist extremists responsible for taking hostage U.S. nationals.

Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with SCG Plastics Co., Ltd., part of a multinational enterprise headquartered in Bangkok, Thailand. SCG Plastics has agreed to pay $20,000,000 to settle its potential civil liability for 467 apparent violations of OFAC sanctions on Iran.

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