The Office of Foreign Assets Control this week published in the Federal Register a previously issued general license under its Syrian Sanctions Regulations. The notice includes the full text of the license.
Five people from Iran, Turkey and the United Arab Emirates were charged in two cases at the U.S. District Court for the District of Columbia for violating the Arms Export Control Act and the International Emergency Economic Powers Act, DOJ announced. They allegedly tried to obtain and export U.S. technology to Iran from 2005 to 2013.
The Office of Foreign Assets Control this week sanctioned four entities and three people in Iran and Turkey for procuring equipment for Iran’s drone and weapons programs. The designations target Farazan Industrial Engineering, a company that has tried to buy tens of thousands of dollars’ worth of European turbine engines for Iran’s unmanned aerial vehicles and missiles, and its managing director Amanallah Paidar. Also sanctioned were Iran’s Defense Technology and Science Research Center; Murat Bukey, a procurement agent; Ozone Havacilik Ve Savunma Sanayi Ticaret Anonim Sirketi, which facilitates Bukey’s business with Iran; Asghar Mahmoudi, who has provided marine electronics to Iran; and Selin Technic, used as a front company by Mahmoudi.
The Office of Foreign Assets Control this week published a previously issued Russia sanctions determination and general licenses. One notice includes a previously issued Russia-related sector determination published under April 15, 2021, executive order, and the others include previously issued general licenses under the Russian Harmful Foreign Activities Sanctions Regulations.
Trade lawyers are expecting a sharp increase in DOJ export control and sanctions prosecutions in the coming months as the agency’s Counterintelligence and Export Control Section undergoes a hiring spree, and several law firms said the increased attention on sanctions violations may cause some companies to bolster their compliance programs.
The Office of Foreign Assets Control this week sanctioned three people in Bosnia and Herzegovina for “undermining stability and perpetuating corruption.” The designations target Osman Mehmedagic, director general of the country’s Intelligence Security Agency; Dragan Stankovic, director of the Republika Srpska Administration for Geodetic and Property Affairs; and Edin Gacanin, “one of the world’s most prolific drug traffickers.” The three “constitute a threat to regional stability, institutional trust, and the aspirations of those seeking democratic governance in the Western Balkans,” Brian Nelson, Treasury’s undersecretary for terrorism and financial intelligence, said March 15.
The Committee on Foreign Investment in the U.S. is placing a significant focus on investments that could present data or cybersecurity risks, said CFIUS head Paul Rosen and FBI official Cynthia Kaiser. Rosen also said CFIUS continues to actively pursue non-notified deals and said the administration is still discussing the idea of an outbound investment review regime.
Iranian national Mehdi Khoshghadam violated U.S. export controls by illegally shipping electrical cables and connectors from the U.S. through Hong Kong and to Iran, DOJ said March 9. Khoshghadam was charged with one count of conspiracy, one count of violating of the International Emergency Economic Powers Act and one count of conspiracy to commit money laundering. The indictment also seeks to forfeit all “proceeds” earned by Khoshghadam from the illegal exports.
Based on 2022 U.S. sanctions enforcement trends, companies should make sure to scale their sanctions compliance programs along with their business expansions, continually conduct audits and make sure employees are properly trained on sanctions compliance, Morrison & Foerster said in a March 6 client alert. The alert explores some of the lessons companies can learn from the Treasury Department’s penalties last year, including that “insufficient oversight” during a merger process can lead to sanctions risks, and all companies -- large or small -- will be held to Treasury’s sanctions compliance standards.
The Office of Foreign Assets Control this week announced a host of new Iran-related sanctions, including new designations against a “shadow banking” network aiding Iranian entities and new sanctions against a network of Chinese companies with ties to the country's unmanned drone industry. The designations target 39 entities illegally allowing Iranian companies to access the international financial system and a network of five companies supporting Iran’s unmanned aerial vehicle procurement efforts.