Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in staying up to date with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2022.
The U.K. updated or amended four of its General Licenses under its Russia sanctions regime, the Office of Financial Sanctions Implementation said last week. The licenses pertain to the oil price cap, "winddown" of positions subject to the oil price cap, correspondent banking and payment processing and projects and countries' exemption from the oil price cap.
The Office of Foreign Assets Control added seven people to its Specially Designated Nationals List in connection with Iranian unmanned aerial vehicle shipments to Russia, it said in a Jan. 6 news release. The designees are six executives and board members of previously designated Qods Aviation Industries (QAI), an Iranian defense manufacturer that designs and produces UAVs being transferred to Russia for use in Ukraine. OFAC also sanctioned the director of Iran’s Aerospace Industries Organization, the "key organization responsible for overseeing Iran’s ballistic missile programs." The agency also updated QAI’s entry on the SDN List to include its new alias, Light Airplanes Design and Manufacturing Industries.
John Sullivan, former deputy secretary of state and U.S. ambassador to Russia, has rejoined Mayer Brown as a partner in the Washington, D.C., and New York offices, the firm announced. Sullivan's practice will center on issues relating to clients' business operations, "including global risk, US sanctions and export controls, international trade disputes and regulation, and foreign investment." Sullivan served as ambassador to Russia from 2020 to 2022 and as acting secretary of state from March to April 2018. He is also a distinguished fellow at Georgetown University's School of Foreign Service and a distinguished senior fellow at Columbia University School of Law's National Security Law Program.
The U.K. updated its guidance on its Russian sanctions regime Jan. 5, the Export Control Joint Unit said. The guidance was changed to "clarify the application of prohibitions on the provision of technical assistance relating to, and making available or transferral of, aviation and space goods and technology or critical-industry goods and technology."
The Commerce Department published its fall 2022 regulatory agenda for the Bureau of Industry and Security, including one new rule that will finalize new chip export controls against China and others that could revise chemical weapons reporting requirements, the Export Administration Regulations and the Entity List.
Taiwan this week expanded its export controls against Russia and Belarus to cover a range of new items that may be used for Russia’s war in Ukraine, including “high-tech” military items. The island added 52 new items to the export control list, saying they are “primarily related” to “nuclear energy substances,” chemicals, machine tools and other “miscellaneous goods and materials.” The changes took effect Jan. 4.
The U.S. may consider new export controls to better prevent U.S. parts and components from being used in Iranian drones delivered to Russia, State Department spokesperson Ned Price said this week. Price's comments came the same day CNN reported that parts manufactured by more than a dozen U.S. and Western companies were found in an Iranian drone struck down in Ukraine last year.
Export Compliance Daily is providing readers with the top 20 stories published in 2022. All articles can be found by searching on the titles or by clicking on the hyperlinked reference numbers.
New Manufacturing USA Institutes can help the semiconductor industry reduce costs and accelerate innovation, particularly in emerging technology areas that could soon be subject to export controls, chip companies and industry representatives said in comments to the National Institute of Standards and Technology. They also said the Commerce Department should bar foreign entities from working with Manufacturing USA Institutes if they are subject to U.S. export restrictions or have operations in certain countries, including China.