Companies should closely review the State Department's recently released compliance program guidelines to make sure their own programs are up to date, Hogan Lovells said in a December alert. The firm also said the guidelines, which outlined key elements of an effective compliance program (see 2212060015), give the defense industry, universities and others involved in activities controlled by the International Traffic in Arms Regulations “insight into the regulator’s compliance expectations.” Because the guidelines are similar to those issued by the Bureau of Industry and Security and the Office of Foreign Assets Control, “organizations should expand their policies and procedures to confirm that these elements are captured if they engage in ITAR regulated activities,” the law firm said.

The State Department designated 10 Russian entities this week, adding them to the Office of Foreign Assets Control's Specially Designated Nationals List. Six of the designated entities develop and manufacture technologies used by the Russian navy, including batteries, navigation equipment, automated control systems, combat information systems and other ship machinery. The remaining four entities operate in the "marine sector" of the Russian economy and develop technologies used in research vessels, aircraft, underwater and space vehicles, as well as manufacturing and related services.

The Office of Foreign Assets Control this week updated two entries and deleted three entries from its Specially Designated Nationals List. Both the updated entries are linked to the Islamic State of Iraq and the Levant, and the deleted entries include a Venezuelan aircraft and two people with Nicaraguan addresses. OFAC didn't provide more information.

The Office of Foreign Assets Control added an Iranian prosecutor general, key military and paramilitary officials, and one entity to its Specially Designated Nationals List related to ongoing violence against protesters. Iranian security forces have continued to escalate violence, including the execution of two protesters and multiple death sentences, OFAC said in a Dec. 21 press release. The designations target the "senior official overseeing the prosecution of protestors," the leaders of organizations assaulting and detaining protestors and the company that provides security forces with anti-riot equipment.

The Office of Foreign Assets Control this week issued a new frequently asked question addressing the service provision price cap on Russian oil. New FAQ 1109 explains that petroleum products loaded prior to Feb. 5 and unloaded prior to April 1 are not subject to the price cap. The FAQ also provides an example of a permissible transaction: A U.S. commodities trader signs a contract on Jan. 1 to purchase Russian petroleum products for shipment to a jurisdiction that has not prohibited the import of those products. The trader arranges for the petroleum products to be loaded onto a vessel, which is loaded on Feb. 1 and a bill of lading is issued. The products are then shipped and discharged at the port of destination on Feb. 15. "U.S. insurance companies provide cover for this shipment/voyage and pay out any related claims, as appropriate," OFAC said.

The Senate this week unveiled its fiscal year 2023 government spending package, which includes additional funding for key export control, sanctions and trade priorities. The package also includes another round of emergency defense aid for Ukraine.

The Office of Foreign Assets Control this week announced what it said are "historic steps" to implement new humantiarian-related authrotizations across its sanctions programs in an effort to better allow the flow of aid to sanctioned countries. The move builds on a U.N. Security Council decision earlier this month that established a humanitarian carve-out across sanctions regimes, allowing nongovernmental organizations, banks and others a general license for certain aid-related transactions involving sanctioned jurisdictions (see 2212120054). Treasury said the U.S. is "the first country in the world" to implement the U.N. carveout in its own borders.

The Office of Foreign Assets Control this week published its Illicit Drug Trade Sanctions Regulations. The regulations implement Executive Order 14059, “Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade,” issued on Dec. 15, 2021. OFAC said it intends to supplement the regulations with a more comprehensive set, which may include additional guidance and general licenses. The regulations are in effect Dec. 20.

The Office of Foreign Assets Control on Dec. 16 removed 19 entries from its Specially Designated Nationals list. The entries were sanctioned for counter-narcotics reasons and include people with entities with addresses in Mexico and Colombia. The primary goal for sanctions is behavioral change and the delisted individuals demonstrated a change in behavior and circumstances, a Treasury spokesperson said Dec. 16, adding that the delisted persons are no longer "engaged in sanctionable activities." The spokesperson also said most of the companies deleted from the SDN List are "now defunct."

The Office of Foreign Assets Control designated 18 entities related to Russia's financial services sector, according to a Dec. 15 press release. The State Department also issued a set of Russia sanctions, primarily targeting oligarch Vladimir Potanin, three members of his immediate family and his business network, the department said in a Dec. 15 press release.