The newsletter is provided as a complimentary service to assist exporters with their ITAR and EAR export compliance responsibilities. It provides a summary of recent changes to export control regulations or other regulatory matters of interest that may impact your company’s international trade and export compliance functions. Call us at 703-847-5801 or email info@fdassociates.net with questions or comments.
See also our “Latest Sanctions Fines & Penalties” section below for an update on companies and persons denied export privileges by the United States Government.
REGULATORY UPDATES
The President
President Biden Continues The National Emergency With Respect To Belarus
June 14, 2023: 88 Fed. Reg. 39109: In accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden has continued for one year the national emergency with respect to Belarus declared in Executive Order 13405 of June 16, 2006, as expanded in scope by Executive Order No. 14038 of August 9, 2021.
President Biden Continues The National Emergency With Respect To The Western Balkans
June 22, 2023: 88 Fed. Reg. 40683: In accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden has continued for one year the national emergency declared in Executive Order 13219 of June 26, 2001, which was expanded in scope in Executive Order 14033, with respect to the Western Balkans.
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President Biden Continues The National Emergency With Respect To North Korea
June 22, 2023: 88 Fed. Reg. 40681: In accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden has continued for one year the national emergency declared in Executive Order 13466 of June 26, 2008, expanded in scope in Executive Order 13551 of August 30, 2010, addressed further in Executive Order 13570 of April 18, 2021, further expanded in scope in Executive Order 13687 of January 2, 2015, and under which additional steps were taken in Executive Order 13722 of March 15, 2016, and Executive Order 13810 of September 20, 2017, with respect to North Korea.
Department of State, Directorate of Defense Trade Controls (DDTC)
DDTC Name And Address Changes Posted To Website
June 2 through 28, 2023: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Change in address for umlaut Consulting Engineering, S.L., Vía de los poblados 1, Parque Empresarial Alvento, 28033 Madrid, Spain to calle Dulce Chacón 55, 7a Planta, 28050 Madrid, Spain.
- Change in name for Toshiba Electronics Engineering Corporation, Toshiba Electronic Systems Corporation, and Toshiba Electro-Wave Components Co., Ltd. to Toshiba Electronic Technologies Corporation due to merger.
- Change in name and address for General Electric International, Inc., Explora Business Centre Stodulky, Praha 5, 158 00, Czech Republic to GE Aviation Czech s.r.o., Beranovych 65, Praha 9, 199 02, Czech Republic, and all locations in the Czech Republic due to reorganization.
- Change in name and address for General Electric International, Inc., Rond Point Schuman 204, Brussels 1040, Belgium, to GE Europe NV, Rond Point Schuman 2-4, Brussels 1040, Belgium, and all locations in Belgium due to reorganization.
- Change in name for Altran Deutschland S.A.S. & Co. KG to Capgemini Engineering Deutschland S.A.S. & Co. KG due to acquisition.
- Change in name and address for Pennine Tools Aerospace Ltd., Unit 1, Ravenscroft Business Park, Jackdaw Road, Barnoldswick, Lancashire BB18 6DX, United Kingdom to Buoyancy Aerospace V1 Ltd. (dba Buoyancy Aerospace), Jackdaw Road, Barnoldswick, Lancashire BB18 6DX, United Kingdom due to merger.
- Change in name and address for General Electric International, Inc., 204 Rond-Point du Pont de Sevres, Citylights, Boulogne-Billancourt 92100, France to GE Aviation Systems France SARL, 17 Avenue Didier Daurat Immeuble Socrate, Blagnac 31700, France, and all locations in France, due to corporate reorganization.
- Change in name for General Electric International, Inc. (Netherlands Operations) to GE Aviation Netherlands B.V. due to reorganization.
- Change in name for General Electric International, Inc. (Ireland Operations) to GE Management Services Ireland Limited due to corporate reorganization.
- Change in Name for General Electric Company Polska Sp. z.o.o. to GE Aerospace Poland Sp. z.o.o. due to corporate reorganization.
- Change in Address for Agile Space Industries, Inc., from 1334 Airport Rd., Durango, CO 81303, to 1514 Main Ave., Durango, CO 81301.
- Change in Name for SPX Corporation to SPX Technologies, Inc.
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The Directorate Of Defense Trade Controls (DDTC) Updates Two Open General Licenses Issued in July 2022, Extending the Validity by Three Years
June 1, 2023: 33 FR 35992: The Department of State, Directorate of Defense Trade Controls (DDTC) published a notice in the Federal Register to inform the public that it published two updated open general licenses, which extend the validity period by two years. The update also addresses ITAR citations changed by the rewrite of Part 120 in the Fall of 2020.
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The Department of State Deploys New Renewal Fee Details Function In DECCS
June 26, 2023: The Department of State’s IT Modernization Team will deploy the new “Renewal Fee Details” functionality to the DECCS Registration application. This feature will be visible to Registration application users who fulfill the following criteria:
- 90 days or fewer remaining prior to the Registration expiration date;
- Organization is subject to a Tier 2 or Tier 3 registration renewal fee**; and
- Organization has at minimum one or more licenses “Approved” or “Approved with Provisos” in the twelve-month window ending 90 days before Registration expiration.
Registration tiers are based on the number of license applications submitted by the registrant. Tier 1 registrants are those submitting an initial registration application, registrants who have not submitted any license applications during the preceding 12 months, and non-profit registrants. The set fee for Tier 1 registrants is $2,250. Tier 2 registrants are those renewing their registration who have submitted 1-10 license applications during the preceding 12 months. The set fee for Tier 2 registrants is $2,750. Tier 3 registrants are those renewing their registration who have submitted more than ten license applications during the preceding 12 months. The fee for Tier 3 registrations is based at $2,750 and increases by $250 for every license application after the 10th application.
Provided the above criteria are met, users will see a new “Renewal Fee Details” button in their Registration dashboard when there are 90 days or less before the expiration date. Selecting this button will display a pop-up window featuring additional details and information on how the renewal fee was calculated. Users will now be able to see the following information consolidated into the new Renewal Fee Details window:
- Registration expiration date;
- License Period “Start” and “End” dates;
- Any licenses which were either “Approved” or “Approved with Provisos” within this date range were incorporated in the calculation of renewal fees;
- Number of Licenses;
- Any licenses which were “Returned Without Action” (RWA) will not be included in the calculation of renewal fees;
- DS-4294 & DS-6004 licenses are not included in the calculation of renewal fees;
- Total License Value;
- 3% of Total License Value Reduced Fee (Tier 3 Renewals Only)**;
- The 3% of Total License Value Reduced Fee field is provided only for calculation purposes and will not be applicable to all organizations. Please see the “Payment of Registration” website page to determine your organization’s renewal fee tier and discount fee eligibility; and
- Renewal Fee Charged By DDTC.
Within this pop-up window, users will be presented with a “Download Licenses” button which generates a .csv file of all licenses considered when calculating the renewal fee charged by DDTC. This .csv file will include the case number, license type, approval date, and license value of all licenses “Approved” or “Approved with Provisos” within the license period date range that were used in the calculation of the renewal fee.
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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Department of Defense
The Netherlands – MK 41 Vertical Launching System (VLS)
June 2, 2023: The State Department made a determination approving a possible Foreign Military Sale to the Government of the Netherlands of MK 41 Vertical Launching Systems (VLS) Baseline (B/L) VII Strike Length Launcher Modules (either system or standalone) and related equipment for an estimated cost of $110 million. The Defense Security Cooperation Agency delivered the required certification notifying Congress of this possible sale today.
The Government of the Netherlands has requested a possible purchase of eight (8) eight-cell MK 41 Vertical Launching Systems (VLS) Baseline (B/L) VII Strike Length Launcher Modules (either system or standalone). Also included are spare parts; handling equipment; transportation test and support equipment; software; engineering/technical assistance; personnel training and training equipment; documentation, publications, and technical data; U.S. Government and contractor technical assistance; and other related elements of logistics and program support. The total estimated program cost is $110 million.
This proposed sale will support the foreign policy and national security objectives of the United States by improving the security of a NATO ally that is an important force for political stability and economic progress in Europe. It is vital to the U.S. national interest to assist the Netherlands in developing and maintaining a strong and ready self-defense capability.
The proposed sale will provide a defensive capability for the Netherlands while enhancing interoperability with the U.S. and other allied forces. The Royal Netherlands Navy intends to use the MK 41 VLS Baseline (B/L) VII strike-length launcher modules for their new ship class. These modules are intended for ESSM BLK1 and SM-2 capabilities in support of ongoing and emergent operational needs. The Netherlands has previously purchased MK 41 VLS capability and actively uses it on their current ship classes. The Netherlands will have no difficulty absorbing this equipment and support into its armed forces. The proposed sale of this equipment and support will not alter the basic military balance in the region.
The prime contractor will be Lockheed Martin Corporation, Bethesda, MD. There are no known offset agreements proposed in connection with this potential sale. Implementation of the proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to the Netherlands. However, U.S. Government or contractor personnel in-country visits will be required on a temporary basis in conjunction with program technical oversight and support requirements. There will be no adverse impact on U.S. defense readiness as a result of this proposed sale.
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DSCA Notifies Congress Of Potential FMS Sale To The Netherlands
June 2, 2023: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) has notified Congress that the Government of the Netherlands has requested a possible purchase of eight (8) eight-cell MK 41 Vertical Launching Systems (VLS) Baseline (B/L) VII Strike Length Launcher Modules (either system or standalone). Also included are spare parts; handling equipment; transportation test and support equipment; software; engineering/technical assistance; personnel training and training equipment; documentation, publications, and technical data; U.S. Government and contractor technical assistance; and other related elements of logistics and program support. The total estimated program cost is $110 million. The prime contractor will be Lockheed Martin Corporation, Bethesda, MD. There are no known offset agreements proposed in connection with this potential sale.
https://www.dsca.mil/press-media/major-arms-sales/netherlands-mk-41-vertical-launching-system-vls
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DSCA Notifies Congress Of Potential FMS Sale To France
June 13, 2023: The Government of France has requested to buy additional non-MDE E-2C Hawkeye sustainment items and services that will be added to a previously implemented case. The original FMS case, valued at $99.6 million, included E-2C Hawkeye sustainment support. Therefore, this notification is for E-2C Hawkeye sustainment support to include an Engine Component Improvement Program (CIP); software updates; technical publications; U.S. Government and contractor technical/product support/assistance; and other related elements of logistics and program support. The estimated total cost is $160 million. The principal U.S. contractor will be Northrop Grumman, Melbourne, FL. There are no known offset agreements proposed in connection with this potential sale.
https://www.dsca.mil/press-media/major-arms-sales/france-e-2c-hawkeye-sustainment-support
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DSCA Notifies Congress Of Potential FMS Sale To Kuwait
June 13, 2023: The Government of Kuwait has requested the continuation of contractor-provided engineering technical services; contractor maintenance services; Hush House (an enclosed, noise-suppressed aircraft jet engine testing facility) support services; and Liaison Office Support for the Government of Kuwait’s F/A-18 C/D/E/F program, to include: F/A-18 avionics software upgrades; engine component improvements; ground support equipment; engine and aircraft spares and repair parts; publications and technical documentation; Engineering Change Proposals (ECP); U.S. Government and contractor programmatic, financial, and logistics support; maintenance and engineering support; F404/F414 engine and engine test cell support; and other related elements of logistical and program support. This proposed sale will provide follow-on sustainment support to Kuwait’s F/A-18C/D/E/F aircraft. The estimated cost is $1.8 billion. The principal contractors will be Sigmatech, Inc., Huntsville, AL; Kay and Associates, Inc., Buffalo Grove, IL; Kellogg, Brown, and Root, Houston, TX; L3 Technologies, Melbourne, FL; The Boeing Company, St. Louis, MO; General Electric, Lynn, MA; Industrial Financial Services, Ottawa, ON; and Lockheed Martin, Orlando, FL. Additional principal contractors will be determined by a competitive contractual award process. There are no known offset agreements proposed in connection with this potential sale.
https://www.dsca.mil/press-media/major-arms-sales/kuwait-follow-technical-support
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DSCA Notifies Congress Of Potential FMS Sale To Spain
June 14, 2023: The Government of Spain has requested to buy an additional one hundred fifty-three (153) M982A1 Excalibur tactical projectiles that will be added to a previously implemented case whose value was under the congressional notification threshold. The original FMS case, valued at $21.87 million, included one hundred eighteen (118) M982A1 Excalibur tactical projectiles. This notification is for a combined total of two hundred seventy-one (271) M982A1 Excalibur tactical projectiles. Also included is a portable electronic Fire Control System (FCS); Improved Platform Integration Kit; Propelling Charge Modular Artillery Charge System; Simple Key Loaders (SKL); crypto cable; training aids; technical data; U.S. Government technical assistance; transportation; Excalibur spare parts; artillery cleaning sections; new equipment training; repair and return support equipment; support related to collateral damage estimation tables; and other related elements of logistics and program support. The total estimated cost is $48.2 million. The principal contractor will be Raytheon Company Missile Systems, McAlester, OK. There are no known offset agreements proposed in connection with this potential sale. Implementation of this sale will not require the assignment of any U.S. Government or contractor representatives to Spain.
https://www.dsca.mil/press-media/major-arms-sales/spain-excalibur-projectiles
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DSCA Notifies Congress Of Potential FMS Sale To The Netherlands
June 16, 2023: The Government of the Netherlands has requested to buy up to four (4) MQ-9A Block 5 aircraft; up to three (3) UAV MQ-9 Mobile Ground Control Systems (MGCS); up to thirty (30) Embedded Global Positioning Systems/Internal Navigation Systems (EGI) devices, Airborne, with Selective Availability Anti-Spoofing Module (SAASM) or M-Code; up to eight (8) AN/DAS-4 Multi-Spectral Targeting Systems; and up to twenty (20) Lynx AN/APY-8 Synthetic Aperture Radars. Also included are Reaper Engines; Selex Seaspray Synthetic Aperture Radars; SeaVue Maritime Radars; M299 Hellfire Longbow missile launchers; AN/ARC-210 radios; Line-of-Site (LOS) Ground Data Terminals; Ruggedized Aircraft Maintenance Test Stations (RAMTS); AN/APX-119 and other Identification Friend or Foe transponders; KIV-77 Cryptographic Appliques; KY-100M narrowband/wideband terminals; AN/PYQ-10 Simple Key Loaders; satellite communications earth terminal subsystems (SETSS); spare parts, consumables, and accessories and repair and return support; secure communication equipment and cryptographic devices; major/minor modifications, maintenance, and maintenance support; munitions support and support equipment; unclassified software delivery and support; transportation support; unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical and logistics support services; and other related elements of logistic and program support. The estimated total cost is $611 million. The principal contractor will be General Atomics-Aeronautical Systems, Poway, CA. There are no known offset agreements proposed in connection with this potential sale.
https://www.dsca.mil/press-media/major-arms-sales/netherlands-mq-9a-block-5-aircraft
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DSCA Notifies Congress Of Potential FMS Sale To Canada
June 27, 2023: The U.S. Department of Defense's Defense Security Cooperation Agency (DSCA) has notified Congress that the Government of Canada has requested to buy up to sixteen (16) P-8A Patrol Aircraft; up to twenty-six (26) Multifunctional Information Distribution System Joint Tactical Radio System 5 (MIDS JTRS 5); up to thirty-eight (38) Embedded Global Positioning Systems (GPS)/Inertial Navigation Systems (EGIs) for the LN-251; up to twenty-five (25) System Processor Replacements for AN/AAQ-24(V)N Large Aircraft Infrared Countermeasures (LAIRCM) System Processor Replacement (LSPR) with Exelis Embedded GPS Receiver (EGR) integrated with SAASM; and up to twenty-two (22) Guardian Laser Transmitter Assemblies (GLTA) for the AN/AAQ-24(V)N. Also included are commercial engines; Tactical Open Mission Software (TOMS); Electro-Optical (EO) and Infrared (IR) MX-20HD; AN/AAQ-2 Acoustic System; AN/APY-10 Radar; AN/ALQ-240 Electronic Support Measures; NexGen Missile Warning Sensors; AN/ARC-210 RT-2036(C) Radios; AN/PRC-117G Manpack Radios including MPE-S type II with SAASM 3.7; AN/ALQ-213 Electronic Countermeasures; AN/ALE-47 Countermeasures Dispenser Systems; AN/UPX-43 Identification Friend or Foe (IFF) Interrogators; AN/APX-123A(V) IFF Digital Transponders; KIV-78 IFF Mode 4/5 Cryptographic Appliques; KIV-701A Cryptographic Core Modules; KY-100M, KY-58, KYV-5 for HF-121C radios; KG-175 Encryptor Network Convergence System; AN/PYQ-10 V3 Simple Key Loaders (SKL) with KOV-21 Cryptographic Appliques; Radiant Mercury Hardware and Software with ENTR(V)4 Receiver with Embedded Crypto for the Integrated Broadcast System (IBS); software; publications; Dual KIV-7M with Power Supply HFIP Channel Link Encryptor; Advanced Digital Antenna Production (ADAP) Antenna Electronics (AE); Advanced Digital Antenna Production (ADAP) Controlled Reception Pattern Antennas (CRPA); Control Interface Units (CIU) for AN/AAQ-24(V)N LAIRCM; aircraft spares; spare engines; support equipment; operational support systems; training; training devices; maintenance trainer/classrooms; engineering technical assistance (ETA); logistics technical assistance (LTA); Country Liaison Officer (CLO) support; Contractor Engineering Technical Services (CETS); Contractor Logistics Support (CLS); repair and return; transportation; aircraft ferry; other associated training and support; and other related elements of logistics and program support. The estimated total cost is $5.9 billion. The prime contractor will be The Boeing Company, Seattle, WA. There are a significant number of other companies under contract with the U.S. Navy that will provide components, systems, and engineering services during the execution of this effort. While the purchaser typically requests offsets, any offset agreement will be defined in future negotiations between the purchaser and the contractor(s).
https://www.dsca.mil/press-media/major-arms-sales/canada-p-8a-aircraft
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The Department of Defense (DoD) Makes Recommendations To Improve And Accelerate To FMS Process
June 13, 2023: The Department of Defense (DoD) approved a tasking memo from the DoD Foreign Military Sales (FMS) Tiger Team that highlights six key FMS pressure points and directs the implementation of recommendations to improve and accelerate the Department's institutional processes to execute FMS cases. The efforts of the Tiger Team and the Department's commitment to improving the FMS system advance the direction of the 2022 National Defense Strategy to break down barriers to working with allies and partners.
The Tiger Team analyzed representative case studies at all phases of the FMS process, illuminated best practices to benchmark, and identified systemic challenges endemic in DoD's FMS ecosystem. The team reviewed the findings of historical reform efforts and also solicited and incorporated feedback from allies and partner nations, and the U.S. industry on ways to improve the efficiency of DoD's implementation of the FMS process.
The FMS-implementing agencies were instructed to:
- Improve the Department's understanding of ally and partner requirements. To accelerate discussions with allies and partner nations about FMS requirements and reduce delays during the FMS case lifecycle, the Department will change the way it organizes, trains, and equips for security cooperation, including by establishing a Defense Security Cooperation Service on par with the Defense Attaché Service;
- Enable efficient reviews for the release of technology. To reduce barriers to the export of key capabilities, the Department will review and update relevant policies and empower accountable officials to improve the efficiency of the review and release of technology to allies and partner nations. The Department will also continue to support interagency efforts focused on technology review and release;
- Provide allies and partner nations with relevant priority capabilities. To better enable allies and partner nations to support their own national security needs, the Department of Defense will develop a methodology to facilitate Non-Programs of Record;
- Accelerate acquisition and contracting support. To advance FMS acquisition prioritization and award timelines for allies and partner nations, the Department will establish contract award standards and metrics as well as develop associated process maps to monitor the FMS prioritization and award process;
- Expand Defense Industrial Base (DIB) capacity. To reduce production timelines, the Department will incorporate ally and partner requirements into ongoing efforts to expand DIB production capacity. This will include developing a comprehensive study to incentivize DIB investment in production capacity and building surge capability for high-demand, low-supply platforms, systems, and services. The strategy will include the use of multi-year contracts; enhanced use of the Special Defense Acquisition Fund; five-year predictive analyses of partner demand; and sustained engagement with the DIB; and
- Ensure broad U.S. Government support. Recognizing that DoD is part of the broader U.S. Government FMS ecosystem, the Department will work with the Department of State and other stakeholders, including Congress, to identify opportunities to improve the FMS process.
To implement these recommendations and ensure the elevation of emergent FMS issues to senior leadership, the Department established an FMS Continuous Process Improvement Board (CPIB), which will act as an enduring governance structure within the Department. The Board, which reports to the Secretary of Defense, will provide accountability in implementing the recommendations, measuring impact, and continually pursuing areas to improve the overall process.
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U.S. Census Bureau
Tips on How to Resolve AES Response Messages
June 21, 2023: To help the industry take the appropriate action for the different AES Response Messages, below are two tips on how to address the most frequent messages that were generated in AES for this month.
Response Code: 303
Narrative: Sold En Route Indicator Must be Y or N
Severity: Fatal
Reason: The Party Type is identified as Ultimate Consignee, and the Sold En Route Indicator is not reported as Yes or No.
Resolution: The Ultimate Consignee information must be reported on an EEI, including a valid Sold En Route Indicator. If the Ultimate Consignee is known and reported, set the Sold En Route Indicator to No. If the cargo is to be Sold En Route and the ultimate consignee is not known at the time of export, then set the Sold En Route Indicator to Yes.
Verify the Ultimate Consignee and the Sold En Route Indicator, correct the shipment, and resubmit.
Response Code: 331
Narrative: Ultimate Consignee Country Unknown
Severity: Fatal
Reason: The Ultimate Consignee Country code reported is not valid in AES.
Resolution: The Ultimate Consignee Country code must be a valid ISO Country code found in Appendix C – ISO Country Codes.
Verify the Ultimate Consignee Country code, correct the shipment, and resubmit.
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The Department of Commerce, the Department of Justice, the Department of State, and the Department of the Treasury
The Department Of Commerce, The Department Of Justice, The Department Of State, And The Department Of The Treasury Issued Guidance To Industry On Iran’s UAV-Related Activities
June 9, 2023: The Department of Commerce, the Department of Justice, the Department of State, and the Department of the Treasury issued guidance to industry on Iran’s UAV-Related activities. Iran’s procurement, development, and proliferation of unmanned aerial vehicles (UAVs) is an increasing threat to international peace and security. The Department of Commerce, the Department of Justice, the Department of State, and the Department of the Treasury are issuing this advisory to alert persons and businesses globally to the threat of Iran’s UAV-related activities and the need to take appropriate steps to avoid or prevent any activities that would support the further development of Iran’s UAV program. The United States is committed to countering Iran’s UAV programs, including by preventing abuse of the U.S. financial system and disrupting the procurement of foreign-sourced components. It is critical that private industry be aware of its legal obligations vis-à-vis entities and items involved in such procurement efforts, given the potential applicability of U.S. export controls and sanctions. The intent of the advisory is to highlight effective due diligence policies, compliance structures, and internal controls relevant specifically to Iran’s UAV-related activities to ensure compliance with applicable legal requirements across the entire supply chain. The advisory is also designed to help prevent companies from contributing to Iran’s UAV programs, including via direct and indirect transfers to third-country suppliers, which may threaten the broader national and international security interests of the United States and its allies and partners.
https://ofac.treasury.gov/media/931876/download?inline
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
OFAC To Retire Its Public-Facing File Transfer Protocol (FTP) Server
June 9, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) will retire its public-facing file transfer protocol (FTP) server (ofacftp.treas.gov) on or about June 10, 2024. In order to comply with updated Treasury security policies, OFAC will retire the FTP capability associated with the file transfer protocol. OFAC is aware that many users utilize ofacftp.treas.gov to automate their sanctions list data downloads. OFAC will maintain this server for one additional calendar year to allow users sufficient time to develop automation that utilizes the list content hosted on the agency's website at the following URLs listed below. Members of the public may contact OFAC at O_F_A_C@treasury.gov for technical support related to this decision.
https://ofac.treasury.gov/recent-actions/20230609_33
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The U.S. OFAC And UK’s OFSI Published A Joint Humanitarian Assistance And Food Security Fact Sheet
June 28, 2023: In furtherance of the recent commitments by the United States and the United Kingdom to protect humanitarian activity from the unintended impacts of sanctions and in support of the enhanced partnership between the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) and His Majesty’s Treasury’s Office of Financial Sanctions Implementation (OFSI), OFAC and OFSI are publishing a joint Humanitarian Assistance and Food Security Fact Sheet to provide additional clarity on U.S. and UK Russia-related sanctions and the relevant authorizations, exceptions, and public guidance.
OFAC and OFSI continue to work together and with foreign partners to reduce the impacts of Russia’s war on global food supplies and prices and to address humanitarian concerns associated with sanctions.
https://ofac.treasury.gov/recent-actions/20230628 and https://ofac.treasury.gov/media/931946/download?inline
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This section of our newsletter provides information on the latest sanctions, fines, and penalties for export violations or matters of non-compliance with the ITAR or EAR issued by the US government enforcement agencies. It is provided as a service to exporters and associates of FD Associates to remind them of the importance of extreme due diligence in all international trade and export compliance matters, particularly those involving exports subject to the ITAR or the EAR. Don't let this happen to you or your company! Call us with questions or concerns at 703-847-5801 or email info@fdassociates.net.
Sanctions
The U.S. Department of State:
June 12, 2023: 88 Fed. Reg. 38118: The U.S. Department of State has determined that the persons known as Maxamed Siidow (also known as Maxamed Siidow Sheikh Ibrahim), Cali Yare (also known as Ali Yare), Maxamed Dauud Gabaane (also known as Maxamed Daud Qaawane, Maxamed Daud, Mahamud Daud), Suleiman Cabdi Daoud (also known as Suleiman Daoud Goobe, Saleban Goobe, Saleeban Goobe), Mohamed Omar Mohamed (also known as Mohamed Omar Ma'alin, Maxamed Cumar Maxamed, Ma'd Umurow, Mohamed Omar Haji, Mohamed Haji Omar Mo'alin, Mohamed Omarow, Ibnu-Omar) are leaders of al-Shabaab, a group whose property and interests in property are currently blocked pursuant to a determination by the Secretary of State pursuant to E.O. 13224 and are designated as Specially Designated Global Terrorists.
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June 15, 2023: 88 Fed. Reg. 39323: The U.S. Department of State published a notice of ten persons statutorily debarred for having been convicted of violating, or conspiring to violate, the Arms Export Control Act (22 U.S.C. 2751, et seq.). This action, pursuant to section 127.7(b) of the International Traffic in Arms Regulations (ITAR) (22 CFR parts 120-130), highlights the Department’s responsibility to protect the integrity of U.S. defense trade. Pursuant to section 38(g)(4) of the AECA and section 127.7(b) and (c)(1) of the ITAR, the following persons, having been convicted in a U.S. District Court, are denied export privileges and are statutorily debarred as of the date of this notice (Name; Date of Judgment; Judicial District; Case No.; Month/Year of Birth):
- Almendarez, Maria Guadalupe; May 10, 2022; Eastern District of Arkansas; 4:19–cr–00116; December 1980.
- Bukey, Murat; a.k.a. Bukey, Murat; a.k.a. Murat, Recep; March 22, 2023; District of Columbia; 1:18–cr–00129; January 1971.
- Cassidy, Kevin Jerome; September 13, 2022; District of Arizona; 2:18–cr– 01236; December 1959.
- Hamade, Usama Darwich; a.k.a. Hamade, Prince Sam; July 22, 2020; District of Minnesota; 0:15–cr–00237; December 1964.
- Pierson, Andrew Scott; April 29, 2022; Eastern District of Arkansas; 4:19– cr–00116; May 1975.
- Radionov, Ihor; August 27, 2021; Middle District of Florida; 8:20–cr– 00308; January 1969.
- Sery, Joe; September 19, 2022; Southern District of California; 3:21–cr– 02898; June 1944.
- Ugur, Arif; December 16, 2022; District of Massachusetts; 1:21–cr– 10221; January 1969.
- Veletanlic, Hany; January 27, 2020; Western District of Washington; 2:18– cr–00162; December 1983.
- Wu, Tian Min; a.k.a. Wu, Bob; a.k.a. Wu, David; a.k.a. Sones, Graham; a.k.a. Wang, Edward; June 9, 2021; Central District of California; 2:17–cr–00081; April 1965.
At the end of the three-year period following the date of this notice, the above-named persons remain debarred unless a request for reinstatement from statutory debarment is approved by the Department of State.
https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=440cf1841befed50d1f1ea02f54bcbcf and https://www.state.gov/u-s-department-of-state-debars-ten-persons-for-violating-or-conspiring-to-violate-the-arms-export-control-act-2/
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June 28, 2023: 88 Fed. Reg. 41997: Acting under the authority of and in accordance with section 1(a)(ii)(B) of E.O. 13224 of September 23, 2001, as amended by E.O. 13268 of July 2, 2002, E.O. 13284 of January 23, 2003, and E.O. 13886 of September 9, 2019, the Department of State determined that the persons known as Arkan Ahmad `Abbas al-Matuti (also known as Arkan Ahmad Abbas Albu-Mazida Albu-Miteuti, Arkan Ahmad `Abbas al-Mitiwiti, and Abu Sarhan) and Nawaf Ahmad Alwan al-Rashidi (also known as Qahtan Nawaf Ahmad Alwan Sada, Nawaf Ahmed Alwan, and Abu Faris) are leaders of ISIS, a group whose property and interests in property are currently blocked pursuant to a determination by the Secretary of State pursuant to E.O. 13224. Arkan Ahmad `Abbas al-Matuti and Nawaf Ahmad Alwan al-Rashidi are designated as Specially Designated Global Terrorists.
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Department of Commerce, Bureau of Industry and Security (BIS)
June 6, 2023: 88 Fed. Reg. 37007: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has renewed the Order temporarily denying the export privileges of Quicksilver Manufacturing, Inc., Rapid Cut LLC, and U.S. Prototype, Inc., for an additional 180 days. OEE’s request for renewal is based upon the facts underlying the issuance of the initial TDO, as well as evidence developed over the continuing course of this investigation. The initial TDO, issued on June 7, 2022, was based on evidence that Respondents engaged in conduct prohibited by the Regulations by exporting or causing the export from the United States of technology controlled on national security and/or missile technology grounds to China for 3D printing without the required U.S. government authorization. In its November 10, 2022, request for renewal of the TDO, BIS submitted evidence that Respondents’ export compliance failures were broader in scope than the investigation initially revealed, as well as evidence related to new concerns raised by actions taken after the issuance of the June 7, 2022, TDO. Specifically, BIS’s evidence and further investigation identified additional U.S. companies that engaged in business with Respondents involving the unlicensed export of technical specifications to China related to firearm components (ECCN 0E501.a) and space-rated items (ECCN 9E515.a), both of which are controlled on national security and regional stability grounds, as well as numerous additional suspected export control-related violations between 2017 and 2022. BIS’s renewal request was also based upon concerns related to Respondents’ initial attempts at compliance following the issuance of the June 7, 2022, TDO, including the provision of potentially inaccurate information to customers about the scope of items subject to the Regulations. In its November 10, 2022, BIS also submitted evidence that a China-based individual, known to operate an @rapidcut.com email address to facilitate Rapid Cut’s business operations, may have violated the TDO shortly after its issuance by providing customer information on how to complete and fulfill pending orders, despite the issuance of the TDO. Such information included instructions to cancel existing Rapid Cut orders and reissue purchase orders to China Company No. 1 in an apparent attempt to avoid the restrictions of the TDO. The May 10, 2023, request for renewal of the December 5, 2022, TDO is also based on evidence related to the nature and scope of BIS’ continuing investigation. This includes the circumstances surrounding the access by China-based employees to Respondents’ email accounts, as detailed above, which remain under investigation. The renewal request is also based on evidence provided by additional U.S. companies that engaged in business with Respondents involving the unlicensed export of technical specifications to China, including information received as recently as April 2023. In sum, and as detailed in the renewal request, BIS' investigation is ongoing, the entirety of Respondent’s misconduct remains unknown, and a final written disclosure of prior violations has not yet been submitted.
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June 7, 2023: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has renewed the Order temporarily denying the export privileges of Belavia Belarusian Airlines for an additional 180 days.
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June 9, 2023: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) issued an Order denying the export privileges of Thomas Harris on March 1, 2022, for ten years until March 1, 2032. Harris was convicted of violating 18 U.S.C. § 554(a) for smuggling and attempting to smuggle 14 firearms from the United States to Saint Lucia. As a result of his conviction, the Court sentenced Harris to 46 months of confinement, three years of supervised release, and a $1,500 assessment.
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June 12, 2023: 88 Fed. Reg. 38739: The Department of Commerce amended the Export Administration Regulations (EAR) by adding 43 entities under 50 entries to the Entity List. These entities have been determined by the U.S. Government to be acting contrary to the national security or foreign policy interests of the United States. These entries are listed on the Entity List under the destinations of China (31), Kenya (1), Laos (1), Malaysia (1), Pakistan (4), Singapore (1), South Africa (3), Thailand (1), the United Arab Emirates (5), and the United Kingdom (2). This rule also removes one entity from the Entity List under the destination of Latvia.
China:
- Aviation Industry Corporation of China 612 Institute;
- Aviation International Corporation of China International Simulation Technology Service Co., Ltd.;
- Beijing China Aviation Technology Co., Ltd.;
- Beijing Iwintall Technology Co. Ltd.;
- Beijing Luo Luo Technology Development Co., Ltd.;
- Beijing Ryan Wende Science and Technology Co., Ltd.;
- Beijing Transemic Information Technology Ltd.;
- Beijing Transemic Technology Ltd.;
- Belt Consulting Co., Ltd.;
- Changzhou Utek Composite Co., Ltd.;
- Chengdu Poyotencon Technology;
- China Taly Aviation Technologies Corporation;
- Chinese Flight Test Establishment;
- Enhance International Trade Limited;
- Frontier Services Group Limited;
- General Technology Limited;
- Luoyang Institute of Science and Technology;
- New Faith Enterprise Investment Limited;
- Opturn Co., Ltd.;
- Pera Global;
- Qianpu Technology Co., Ltd.;
- Shanghai Aerospace Science and Technology Development Co., Ltd.;
- Shanghai Breeze Technology Co., Ltd.;
- Shanghai Breeze Technology Jiangsu Co., Ltd.;
- Shanghai Shark Sprite Technology Co., Ltd.;
- Shanghai Supercomputing Technology Co., Ltd.;
- The Test Flying Academy of South Africa;
- Tiger Force Electronics Limited;
- United Vision Limited;
- Universal Enterprise Limited; and
- Xinjiang Kehua Hechang Biological Science and Technology Co., Ltd.
Kenya:
- Frontier Services Group Limited.
Laos:
- Frontier Services Group Limited.
Malaysia:
- International Aerospace Asia.
Pakistan:
- Affiliates International;
- Akhtar and Sons Private Limited;
- Imminent Engineering Co., Ltd.; and
- Quantum Logix (Private) Limited.
Singapore:
- International Aerospace Asia.
South Africa:
- AVIC International Flight Training Academy;
- Pearl Coral 1173 CC; and
- The Test Flying Academy of South Africa.
Thailand:
- International Aerospace Asia.
United Arab Emirates:
- Frontier Services Group Limited;
- TFASA Group FZCO;
- TFASA Group Training;
- TFASA Services FZCO; and
- TFASA Training Limited.
United Kingdom
- TFASA Group Limited; and
- International Aerospace Asia.
Removal From the Entity List
The End-User Review Committee determined to remove Fiber Optic Solutions from the Entity List. This is based on information that BIS received pursuant to § 744.16(e) of the EAR and the review that the ERC conducted in accordance with procedures described in supplement no. 5 to part 744 of the EAR. Prior to removal from the Entity List by this rule, Fiber Optic Solutions was listed under Latvia.
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June 15, 2023: The U.S. Department of Commerce's Bureau of Industry and Security (BIS) has renewed for 180 days Temporary Denial Orders (TDOs) against the following three Russian airlines for violations of license requirements it imposed in response to Russia's invasion of Ukraine effective March 2, 2022, on any U.S.-origin aircraft or foreign aircraft that includes more than 25% controlled U.S.-origin content, and that is registered in, owned, or controlled by, or under charter or lease by Russia or a national of Russia, before such aircraft can travel to Russia:
- Pobeda Airlines;
- Nordwind Airlines and Pegas Touristik, a/k/a Pegas Touristik OOO;
- Siberian Airlines d/b/a S7 Airlines.
https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2023/1533-e2871/file and https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2023/1534-e2872/file and https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2023/1535-e2873/file
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June 21, 2023: 88 Fed. Reg. 40084: The Department of Commerce is amending the Export Administration Regulations (EAR) by adding an inadvertently omitted entity to the Entity List. This correcting amendment is effective June 16, 2023.
China:
- China Aviation Development Harbin Bearing Co., Ltd.
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS Removed Pegas Touristik from the Temporary Denial Order
June 28, 2023: The Department of Commerce, Bureau of Industry and Security removed Pegas Touristik from the Temporary Denial Order of Nordwin.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
June 1, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Sudan General License Number 1, "Official Business of Certain International Organizations and Entities;" Sudan General License Number 2, "Certain Transactions in Support of Nongovernmental Organizations’ Activities;" Sudan General License Number 3 "Transactions Related to the Provision of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates, and the Extraction, Processing, Transport, Sale, or Distribution of Water in Sudan;" and Sudan General License Number 4 "Authorizing the Wind Down of Transactions Involving Defense Industries System or Al Junaid Multi Activities Co Ltd."
Sudan General License Number 1: All transactions prohibited by Executive Order (E.O.) 14098 that are for the conduct of the official business of the following entities by employees, grantees, or contractors thereof are authorized:
(1) The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA);
(2) The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing;
(3) The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies;
(4) The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance;
(5) The African Union, including the African Union Commission and other subsidiary bodies and organs; and
(6) The Intergovernmental Authority on Development (IGAD).
This general license does not authorize funds transfers initiated or processed with knowledge or reason to know that the intended beneficiary of such transfers is a person blocked pursuant to E.O. 14098 other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services.
https://ofac.treasury.gov/media/931821/download?inline
Sudan General License Number 2: All transactions prohibited by Executive Order (E.O.) 14098 that are ordinarily incident and necessary to the activities described below by nongovernmental organizations are authorized, provided that the nongovernmental organization is not a person whose property or interests in property are blocked pursuant to E.O. 14098.
The activities referenced above are non-commercial activities designed to directly benefit the civilian population that fall into one of the following categories:
(1) Activities to support humanitarian projects to meet basic human needs, including disaster, drought, and flood relief; food, nutrition, or medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs;
(2) Activities to support democracy building, including activities to support the rule of law, citizen participation, government accountability and transparency, human rights, and fundamental freedoms, access to information, and civil society development projects;
(3) Activities to support education, including combating illiteracy, increasing access to education, international exchanges, and assisting education reform projects;
(4) Activities to support non-commercial development projects directly benefitting civilians, including those related to health, food security, and water and sanitation;
(5) Activities to support environmental and natural resource protection, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage; and
(6) Activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs.
This general license does not authorize funds transfers initiated or processed with knowledge or reason to know that the intended beneficiary of such transfers is a person blocked pursuant to E.O. 14098 other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services.
Specific licenses may be issued on a case-by-case basis to authorize nongovernmental or other entities to engage in other activities designed to directly benefit the civilian population, including support for the removal of landmines and economic development projects directly benefiting the civilian population.
https://ofac.treasury.gov/media/931826/download?inline
Sudan General License Number 3: All transactions prohibited by Executive Order (E.O.) 14098 of May 4, 2023, that are related to the provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Sudan or to persons in third countries purchasing specifically for resale to Sudan, are authorized.
All transactions prohibited by E.O. 14098 that are related to the extraction, processing, transport, sale, or distribution of water, including the maintenance or repair of water pipelines, are authorized.
For the purposes of this general license, agricultural commodities, medicine, and medical devices are defined as follows:
(1) Agricultural commodities. Agricultural commodities are products:
(i) That fall within the term “agricultural commodity” as defined in section 102 of the Agricultural Trade Act of 1978 (7 U.S.C. 5602); and
(ii) That are intended for ultimate use in Sudan as (A) Food for humans (including raw, processed, and packaged foods; live animals; vitamins and minerals; food additives or supplements; and bottled drinking water) or animals (including animal feeds); (B) Seeds for food crops; (C) Fertilizers or organic fertilizers; or (D) Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food animals.
(2) Medicine. Medicine is an item that falls within the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
(3) Medical devices. A medical device is an item that falls within the definition of “device” in section 201 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321).
https://ofac.treasury.gov/media/931831/download?inline
Sudan General License Number 4: All transactions prohibited by Executive Order (E.O.) 14098 that are ordinarily incident and necessary to the wind-down of any transaction involving Defense Industries System, Al Junaid Multi Activities Co Ltd, or any entity in which Defense Industries System or Al Junaid Multi Activities Co Ltd owns, directly or indirectly, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, July 31, 2023, provided that any payment to a blocked person must be made into a blocked account and reported to the Office of Foreign Assets Control consistent with § 501.603 of the Reporting, Procedures and Penalties Regulations, 31 CFR part 501.
This general license does not authorize any transactions otherwise prohibited by E.O. 14098, including transactions involving any person blocked pursuant to E.O. 14098 other than the blocked persons described in paragraph (a) of this general license, unless separately authorized.
https://ofac.treasury.gov/media/931836/download?inline
OFAC also designated members and affiliates of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its external operations arm, the IRGC-Qods Force (IRGC-QF), who have participated in a series of terrorist plots including assassination plots targeting former United States government officials, dual U.S. and Iranian nationals, and Iranian dissidents. This action targets three Iran- and Türkiye-based individuals and a company affiliated with the IRGC-QF, along with two senior officials of the IRGC’s Intelligence Organization (IRGC-IO), who have been involved in plotting external lethal operations against civilians, including journalists and activists.
OFAC also designated four companies generating revenue from, and contributing to, the conflict in Sudan. The entities designated are affiliated with the two embattled forces that are fueling the ongoing conflict in Sudan: two companies affiliated with the paramilitary Rapid Support Forces (RSF) and two companies affiliated with the Sudanese Armed Forces (SAF).
In addition, the following changes have been made to OFAC's list of Specially Designated Nationals:
The following individuals have been added to OFAC's SDN List:
- Hossein Hafez Amini of Iran
- Mohammad Reza Ansari of Iran
- Rouhollah Bazghandi of Iran
- Shahram Poursafi of Syria
- Reza Seraj of Iran
The following entities have been added to OFAC's SDN List:
- Al Junaid Multi Activities Co Ltd of Sudan
- Defense Industries System of Sudan
- Rey Havacilik Ithalat Ihracat Sanayi Ve Ticaret Anonim Sirketi, of Turkey
- Sudan Master Technology of Sudan
- Tradive General Trading L.L.C of The U.A.E.
The following deletions have been made to OFAC's SDN List:
- Alfa Nero (ZCTL4) Yacht 2,159GRT Cayman Islands flag of Russia
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June 2, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Iran-related General License P "Authorizing the Wind Down of Transactions Involving Navyan Abr Arvan Private Limited Company or Arvancloud Global Technologies L.L.C."
In addition, the following changes have been made to OFAC's list of Specially Designated Nationals:
The following individuals have been added to OFAC's SDN List:
- Farhad Fatemi of Iran.
- Pouya Pirhosseinloo of Iran
The following entities have been added to OFAC's SDN List:
- Arvancloud Global Technologies L.L.C. of The United Arab Emirates
- Navyan Abr Arvan Private Limited Company of Iran
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June 5, 2023: The Department of the Treasury's Office of Foreign Assets Control (OFAC) published four general licenses (GLs) issued pursuant to the Russian Harmful Foreign Activities Sanctions Regulations: GLs 13E, 66, 67, and 68, each of which was previously made available on OFAC's website.
June 5, 2023: The Department of the Treasury's Office of Foreign Assets Control (OFAC) published one Russian Harmful Foreign Activities Sanctions directive in the Federal Register. The directive, issued pursuant to an April 15, 2021, Executive Order, was previously made available on OFAC's website.
June 5, 2023: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated seven leading members of a Russian intelligence-linked malign influence group for their role in the government of the Russian Federation’s destabilization campaign and continued malign influence campaigns in Moldova. An entity owned or controlled by one of these individuals has also been designated.
These designations are part of an ongoing effort to combat Russia’s malign influence in Moldova. The U.S. government has previously exposed Russia’s attempts to use covert operatives to subvert democracy in Moldova. On October 26, 2022, OFAC sanctioned Yuriy Igorevich Gudilin, Olga Yurievna Grak, and Leonid Mikhailovich Gonin for their coordinated efforts in 2020 and 2021 to influence the outcome of Moldova’s elections. Additionally, on May 30, 2023, the EU sanctioned several Russian and Moldovan individuals for engaging in destabilizing activities against the government of Moldova. The U.S. government will continue to support the Moldovan government and people in their efforts to combat coercive activities that undermine democracy in Moldova.
The following individuals have been added to OFAC's SDN List:
- Boyko, Svetlana Andreyevna of Russia;
- Gromovikov, Vasiliy Viktorovich of Russia;
- Khloponin, Gleb Maksimovich of Russia;
- Losev, Aleksey Vyacheslavovich of Russia;
- Makolov, Yury Yuryevich of Russia;
- Sapozhnikov, Konstantin Prokopyevich of Russia; and
- Travnikova, Anna of Russia.
The following entity has been added to OFAC's SDN List:
- Perko Julleuchter of Russia.
https://home.treasury.gov/news/press-releases/jy1522 and https://ofac.treasury.gov/recent-actions/20230605
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June 6, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two senior members of the Cartel de Jalisco Nueva Generacion (CJNG) engaged in trafficking high-caliber firearms from the United States and fuel theft in Mexico. Additionally, OFAC designated another individual and one Mexican entity that provide support to CJNG by laundering illicit narcotics proceeds. CJNG is a violent Mexico-based drug trafficking organization responsible for a significant proportion of fentanyl, and other deadly drugs trafficked into the United States.
OFAC also sanctioned a network of seven individuals and six entities in Iran, the People’s Republic of China (PRC), and Hong Kong in connection with Iran’s ballistic missile program. This network has conducted financial transactions and facilitated procurement of sensitive and critical parts and technology for key actors in Iran’s ballistic missile development, including Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and its affiliated organizations, Parchin Chemicals Industries (PCI), Aerospace Industries Organization (AIO), Iran Electronics Industries (IEI), and P.B. Sadr, which is PCI’s key intermediary for the procurement of parts to develop missile propellant. PCI, the main beneficiary of this network, is a subsidiary of MODAFL’s Defense Industries Organization (DIO) and produces ammunition, explosives, and solid propellants for rockets and missiles. OFAC is also designating Iran’s Defense Attaché in Beijing, which has coordinated military-related procurements from the PRC for Iranian end-users, including MODAFL subsidiaries.
The following individuals have been added to OFAC's SDN List:
- Damghani, Davoud of China and Iran;
- Gong, Jiao of China;
- Guerrero Covarrubias, Alonso of Mexico;
- Guerrero Covarrubias, Javier of Mexico;
- Haghighat, Ghasem of China and Iran;
- Li, Zeming, Zhejiang of China;
- Qin, Xutong, Ji Lin of China;
- Rodriguez Aguirre, Mary Cruz of Mexico;
- Shen, Weisheng, Zhejiang of China; and
- Wei, Zunyi of China.
The following entities have been added to OFAC's SDN List:
- Beijing Shiny Nights Technology Development CO., LTD, of China;
- Blue Calm Marine Services Company of Iran;
- Hong Kong Ke.Do International Trade CO., LIMITED of China;
- Lingoe Process Engineering Limited of China;
- Nacer Agencia Panamericana De Divisas Y Centro Cambiario, S.A. DE C.V., of Mexico;
- Qingdao Zhongrongtong Trade Development CO., LTD. of China; and
- Zhejiang Qingji Ind. CO., LTD of China.
https://home.treasury.gov/news/press-releases/jy1523 and https://home.treasury.gov/news/press-releases/jy1524 and https://ofac.treasury.gov/recent-actions/20230606
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June 8, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism Designations, Iran-related Designations Updates, and a Non-Proliferation Designation Update.
The following individuals have been added to OFAC's SDN List:
- Al-Mainuki, Abu Bakr ibn Muhammad ibn 'Ali of Nigeria; and
- Al-Rufay'i, Abdallah Makki Muslih of Iraq.
https://ofac.treasury.gov/recent-actions/20230608
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June 14, 2023: The United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) is publishing a Fact Sheet on the "Provision of Humanitarian Assistance and Trade to Combat COVID-19." OFAC is also issuing Iran-related General License N-2, Venezuela-related GL 39B, Syria GL 21B, and amending several FAQs.
The United States is committed to ensuring that humanitarian assistance continues to reach at-risk populations through legitimate and transparent channels as countries across the globe fight the Coronavirus Disease 2019 (COVID-19). The sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) generally allow for legitimate humanitarian-related trade, assistance, or activity under existing laws and regulations. OFAC encourages those interested in providing such COVID-19-related assistance to avail themselves of longstanding exemptions, exceptions, and authorizations pertaining to humanitarian assistance and trade available in many U.S. sanctions programs. In the event that individuals, governments, or entities facing sanctions-related challenges have questions related to the provision of humanitarian assistance to sanctioned countries, or believe additional authorizations are needed, OFAC stands ready to provide guidance and respond to applications for specific licenses. This Fact Sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the OFAC-administered Iran, Venezuela, North Korea, Syria, Cuba, and Russia-related sanctions programs.
https://ofac.treasury.gov/media/931896/download?inline
Iran-related General License N-2: Authorized certain COVID-19-related transactions prohibited by the Iranian Transactions and Sanctions Regulations. The following transactions and activities that are prohibited by the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), are authorized through 12:01 a.m. eastern daylight time, June 14, 2024:
(1) Exportation of goods or technology. All transactions and activities related to the exportation, reexportation, sale, or supply, directly or indirectly, of goods or technology for use in connection with the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies related to COVID-19) to Iran or the Government of Iran, or to persons in third countries purchasing specifically for resale to Iran or the Government of Iran;
(2) Importation of or dealings in certain COVID-19-related goods. All transactions and activities related to the importation into the United States of, or dealings in or related to, goods that previously were exported or reexported to Iran or the Government of Iran pursuant to this general license and that are broken, defective, or non-operational, or are connected to product recalls, adverse events, or other safety concerns, or for routine maintenance or the permanent return of such items to the United States or a third country; and
(3) Exportation or importation of services. All transactions and activities related to the exportation, reexportation, sale, or supply, directly or indirectly, of services to Iran or the Government of Iran, or the importation into the United States of, or dealings in or related to Iranian-origin services, in each case that are related to the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19).
https://ofac.treasury.gov/media/931881/download?inline
Venezuela-related General License 39B: All transactions and activities involving the Government of Venezuela that are related to the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19) that are prohibited by Executive Order (E.O.) 13808 of August 27, 2017, as amended by E.O. 13857 of January 25, 2019, or E.O. 13884 of August 5, 2019, each as incorporated into the Venezuela Sanctions Regulations, 31 CFR part 591 (the VSR), are authorized through 12:01 a.m. eastern daylight time, June 14, 2024.
Authorized certain COVID-19-related transactions involving certain banks. All transactions and activities described above involving Banco Central de Venezuela (BCV), Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela), Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentenario del Pueblo), or any entity in which BCV, Banco de Venezuela or Banco Bicentenario del Pueblo owns, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest, that are prohibited by E.O. 13850 of November 1, 2018, as amended by E.O. 13857, each as incorporated into the VSR, are authorized through 12:01 a.m. eastern daylight time, June 14, 2024.
https://ofac.treasury.gov/media/931886/download?inline
Syria General license 21B: Authorized certain COVID-19-related transactions prohibited by the Syrian Sanctions Regulations. The following transactions and activities that are prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR), are authorized through 12:01 a.m. Eastern daylight time, June 14, 2024:
(1) Exportation of services related to COVID-19. All transactions and activities related to the exportation, reexportation, sale, or supply, directly or indirectly, of services to Syria that are related to the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19); and
(2) COVID-19-related transactions involving certain blocked persons. All transactions and activities involving the Government of Syria, Polymedics LLC, Letia Company, or any entity in which Polymedics LLC or Letia Company owns, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest, that are related to the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19), provided that any exportation or reexportation of items to Syria must be licensed or otherwise authorized by the Department of Commerce.
https://ofac.treasury.gov/media/931891/download?inline
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June 15, 2023: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Democratic People’s Republic of Korea (DPRK) nationals involved in the procurement of equipment and materials that support the DPRK ballistic missile program. The DPRK continues to utilize a network of representatives in foreign countries, including the People’s Republic of China (PRC) and Iran, to illicitly import restricted components necessary to conduct research and development of its unlawful weapons of mass destruction (WMD) and ballistic missile programs, in violation of multiple UN Security Council resolutions.
The following individuals have been added to OFAC's SDN List:
- Choe, Chol Min of North Korea; and
- Choe, Un Jong of North Korea.
https://home.treasury.gov/news/press-releases/jy1539 and https://ofac.treasury.gov/recent-actions/20230615
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June 16, 2023: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on the Hernandez Salas transnational criminal organization (TCO), a human smuggling organization based in Mexicali, Mexico, as well as several members and entities in its support network. The practice of human smuggling and the facilitation of fraudulent documentation undermines the U.S. asylum system, damaging public confidence in the vetting process and jeopardizing access to protection for vulnerable persons fleeing conflict, famine, and persecution. Often, migrants encounter violence in each territory they cross on their journey toward the United States and may even end up victims of human trafficking. This action continues the Biden-Harris administration’s whole-of-government effort to confront human smuggling on the southern border of the United States.
According to U.S. Immigration and Customs Enforcement, TCOs earn billions of dollars from human smuggling. Most individuals attempting to enter the United States covertly seek assistance organizing transport across the border; smuggling organizations, often associated with other TCOs, take advantage of those individuals by providing services at a significant cost.
The following individuals have been added to OFAC's SDN List:
- Chavez Tamayo, Jesus Gerardo of Mexico;
- Hernandez Salas, Ofelia of Mexico;
- Hernandez Sanchez, Federico of Mexico;
- Maldonado Lopez, Fatima del Rocio of Mexico; and
- Saucedo Huipio, Raul of Mexico.
The following entities have been added to OFAC’s SDN List:
- Hernandez Salas Transnational Criminal Organization of Mexico;
- Hotel Plaza of Mexico; and
- Hotelera Lopez Mateos S.A. DE C.V. of Mexico.
https://home.treasury.gov/news/press-releases/jy1545 and https://ofac.treasury.gov/recent-actions/20230616
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June 21, 2023: the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Burma’s Ministry of Defense and two regime-controlled financial institutions that facilitate much of the foreign currency exchange within Burma and enable transactions between the military regime and foreign markets, including for the purchase and import of arms and related materiel.
OFAC also issued the Burma-related General License 5, "Authorizing the Wind Down of Transactions Involving Myanma Investment and Commercial Bank or Myanma Foreign Trade Bank."
Burma-related General License 5: All transactions prohibited by Executive Order 14014 that are ordinarily incident and necessary to the wind-down of transactions involving Myanma Investment and Commercial Bank (MICB), Myanma Foreign Trade Bank (MFTB), or any entity in which MICB or MFTB owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, are authorized through 12:01 a.m. eastern daylight time, August 5, 2023, provided that any payment to a blocked person must be made into a blocked account in accordance with the Burma Sanctions Regulations, 31 CFR part 525 (BuSR).
This general license does not authorize any transactions otherwise prohibited by the BuSR, including transactions involving any person blocked pursuant to the BuSR other than the blocked persons described in paragraph (a) of this general license, unless separately authorized.
The following entities have been added to OFAC's SDN List:
- Ministry Of Defense Of Burma;
- Myanma Foreign Trade Bank; and
- Myanma Investment And Commercial Bank.
https://home.treasury.gov/news/press-releases/jy1555 and https://ofac.treasury.gov/media/931936/download?inline and https://ofac.treasury.gov/recent-actions/20230621
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June 23, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned two Russian Federal Security Service (FSB) officers recently indicted by the Department of Justice who played a significant role in the Kremlin’s attempts to conduct global malign influence operations, including efforts to influence a local election in the United States.
The following individuals have been added to OFAC's SDN List:
- Popov, Yegor Sergeyevich of Russia; and
- Sukhodolov, Aleksei Borisovich of Russia.
https://home.treasury.gov/news/press-releases/jy1572 and https://ofac.treasury.gov/recent-actions/20230623
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June 27, 2023: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned four companies and one individual connected to the violent Russian military group PMC Wagner (Wagner Group) and its founder and owner Yevgeniy Prigozhin, previously sanctioned by the United States, the European Union (EU), Canada, and the United Kingdom (U.K.). The Wagner Group exploits insecurity around the world, committing atrocities and criminal acts that threaten the safety, good governance, prosperity, and human rights of nations, as well as exploiting their natural resources. The targeted entities in the Central African Republic (CAR), United Arab Emirates (UAE), and Russia have engaged in illicit gold dealings to fund the Wagner Group to sustain and expand its armed forces, including in Ukraine and Africa, while the targeted individual has been central to activities of Wagner Group units in Mali.
The following individual has been added to OFAC's SDN List:
- Ivanov, Nikolayevich Andrey of Russia.
The following entities have been added to OFAC's SDN List:
- Diamville SAU of the Central African Republic;
- Industrial Resources General Trading of the United Arab Emirates;
- Limited Liability Company DM of Russia; and
- Midas Ressources SARLU of the Central African Republic.
OFAC also published an Africa Gold Advisory.
https://home.treasury.gov/news/press-releases/jy1581 and https://ofac.treasury.gov/recent-actions/20230627_33 and https://ofac.treasury.gov/media/931956/download?inline
U.S. Department of Homeland Security
June 12, 2023: 88 Fed. Reg. 38080: The U.S. Department of Homeland Security (DHS), as the Chair of the Forced Labor Enforcement Task Force (FLETF), announces the publication and availability of the updated Uyghur Forced Labor Prevention Act (UFLPA) Entity List, a consolidated register of the four lists required to be developed and maintained pursuant to the UFLPA, on the DHS UFLPA website. The updated UFLPA Entity List is also published as an appendix to this notice. This update adds two entities and eight subsidiaries to the UFLPA Entity List for working with the government of Xinjiang to recruit, transport, transfer, harbor, or receive forced labor or Uyghurs, Kazakhs, Kyrgyz, or members of other persecuted groups out of Xinjiang.
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Fines and Penalties
June 3, 2023: The U.S. Department of State has concluded an administrative settlement with VTA Telecom Corporation to resolve six violations of the Arms Export Control Act (AECA), 22 U.S.C. § 2751 et seq., and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. Parts 120-130. The Department of State and VTA Telecom Corporation reached this settlement following an extensive compliance review by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs.
The administrative settlement between the Department of State and VTA Telecom Corporation, concluded pursuant to ITAR § 128.11, addresses unauthorized exports and attempted exports of ITAR-controlled defense articles, including hobby rocket motors, video trackers, including related technical data, and a gas turbine engine controlled under U.S. Munitions List Categories IV(d)(7), IV(h), IV(h)(11), XII(a), and XIX(c) to Vietnam, a proscribed country for exports and temporary imports of defense articles and defense services, by 22 CFR § 126.1 at the time of the violations.
The settlement demonstrates the Department’s role in furthering world peace and the security and foreign policy of the United States by controlling the export of defense articles. The settlement also highlights the importance of exporting defense articles only pursuant to appropriate authorization from the Department.
Under the terms of the Consent Agreement, VTA Telecom Corporation will be administratively debarred and thereby prohibited from participating directly or indirectly in any activities subject to the ITAR for three years.
https://www.state.gov/u-s-department-of-state-concludes-settlement-resolving-export-violations-by-vta-telecom-corporation/ and https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=99e327b21b4ba990d1f1ea02f54bcb8d and https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=15e363b21b4ba990d1f1ea02f54bcb09 and https://www.pmddtc.state.gov/sys_attachment.do?sysparm_referring_url=tear_off&view=true&sys_id=99e327b21b4ba990d1f1ea02f54bcb8b
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June 7, 2023: A federal judge sentenced Miguel Armando Castro, of Phoenix, to 51 months in prison, followed by supervised release for attempting to smuggle firearms and ammunition into Mexico. The judge also ordered him to pay a $100 special assessment. Castro pleaded guilty to smuggling goods from the United States following a Homeland Security Investigations (HSI) probe. On Jan. 19, 2022, Castro attempted to exit the United States into Mexico in a vehicle lane at the Mariposa Port of Entry in Nogales. Castro was the driver and sole occupant of a Chevrolet Silverado pickup truck. U.S. Customs and Border Protection officials had received alerts on the Silverado and Castro related to a prior ammunition smuggling incident. Upon initial inspection of the Silverado, officers found a bag on the front seat containing a loaded .22-caliber revolver. While inspecting the vehicle, they found two high-capacity Glock firearm magazines, four regular-capacity Glock firearm magazines, and one .22-caliber Walther firearm magazine. The firearm, ammunition, and magazines Castro intended to export to Mexico are designated on the U.S. Commerce Control List as prohibited for export from the United States into Mexico without a valid license. Castro did not have a license or any other lawful authority to export any of the items from the United States into Mexico.
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June 8, 2023: Eric Nana Kofi Ampong Coker, age 41, of Columbia, Maryland, pleaded guilty to the illegal export of firearms to Ghana. According to his guilty plea, since 2017, Ampong Coker has purchased at least 81 firearms from three separate Maryland Federal Firearms Licensees (“FFLs”) and, in 2019, received Regulated Firearms Collector status through the Maryland State Police, which waived the restriction on the number of firearms he could purchase during a 30-day period.
https://www.justice.gov/usao-md/pr/columbia-man-pleads-guilty-illegally-exporting-firearms-ghana
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June 9, 2023: the Department of Commerce, Bureau of Industry and Security (BIS), issued a Temporary Denial Order (TDO) suspending the export privileges of the Aratos Group, a network of defense-related companies in the Netherlands and Greece, and its president, Nikolaos Bogonikolos. These actions are related to a May 22, 2023, criminal indictment issued in the Eastern District of New York and are the result of coordination by the Disruptive Technology Strike Force co-led by the Departments of Justice and Commerce. While Bogonikolos remains in custody, this action builds on the indictment by severing his company, Aratos Group, from access to U.S.-origin items and technologies. The TDO also renews the denial of export privileges against three persons – Boris Livshits, Svetlana Skvortsova, and Aleksey Ippolitov – and two companies – Advanced Web Services and Strandway, LLC – for the unauthorized export of sensitive items subject to the Export Administration Regulations (EAR) to Russia.
https://www.bis.doc.gov/index.php/documents/about-bis/newsroom/press-releases/3285-2023-06-09-bis-press-release-aratos-tdo-final/file and https://efoia.bis.doc.gov/index.php/documents/export-violations/export-violations-2023/1524-e2862/file
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Samet Doyduk for seven years until July 12, 2029. On July 12, 2022, Doyduk was convicted of violating 18 U.S.C. § 371 for conspiring to export firearm parts purchased in the United States to be shipped to Turkey and the Republic of Georgia. As a result of his conviction, the Court sentenced Doyduk to 15 months of imprisonment, three years of supervised release, and a $100 special assessment.
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Shaohua “Eric” Wang for ten years until February 2, 2030. On February 3, 2020, Wang was convicted of violating 18 U.S.C. § 371 for conspiring to willfully export from the United States to China, controlled military equipment and supplies for profit without the required licenses. As a result of his conviction, the Court sentenced Wang to 46 months of confinement, three years of supervised release, a $200 special assessment, and a $25,000 criminal fine.
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Jorge Jesus Sigala for five years until April 22, 2026. On April 22, 2021, Sigala was convicted of violating 18 U.S.C. § 554(a) for smuggling from the United States to Mexico various pistols. As a result of his conviction, the Court sentenced Sigala to 12 months and one day of confinement, three years of supervised release, and a $100 special assessment.
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Eli Espinoza for ten years until December 14, 2030. On December 14, 2020, Espinoza was convicted of violating 18 U.S.C. § 554(a) for smuggling and attempting to smuggle from the United States to Mexico firearms components to include, front trunnion, AK bolt body, upper hand guard and gad tube, rear sight block, recoil spring rear guide, dust cover, trigger for semi-automatic rifle, bolt carrier assembly, and bolt catch, without a license or written approval from the US Department of Commerce. As a result of his conviction, the Court sentenced Espinoza to 63 months of confinement, three years of supervised release, and a $100 assessment.
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Khalid Jarrah for ten years until August 11, 2031. On August 11, 2021, Jarrah was convicted of violating 18 U.S.C. § 371 for conspiring to knowingly, intentionally, and willfully engage in the business of dealing firearms without a license. As a result of his conviction, the Court sentenced Jarrah to 15 months of confinement, three years of supervised release, and a $100 assessment.
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June 10, 2023: The Department of Commerce, Bureau of Industry (BIS) denied the export privileges of Patrick Lee Sousa for ten years until October 29, 2031. On October 29, 2021, Sousa was convicted of violating 18 U.S.C. § 371 for conspiring to knowingly, intentionally, and willfully engage in the business of dealing firearms without a license. As a result of his conviction, the Court sentenced Sousa to 57 months of confinement, three years of supervised release, and a $300 assessment.
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June 20, 2023: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a settlement with Swedbank AS (Latvia) ("Swedbank Latvia"), a subsidiary of Swedbank AB (publ), headquartered in Stockholm, Sweden. Swedbank Latvia has agreed to remit $3,430,900 to settle its potential civil liability for 386 apparent violations of OFAC's Crimea sanctions. Throughout 2015 and 2016, a customer of Swedbank Latvia used Swedbank Latvia's e-banking platform from an internet protocol address in Crimea to send payments to persons in Crimea through U.S. correspondent banks. The settlement amount reflects OFAC's determination that Swedbank Latvia's apparent violations were not voluntarily self-disclosed and were non-egregious.
https://ofac.treasury.gov/recent-actions/20230620_33 and https://ofac.treasury.gov/media/931911/download?inline
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June 20, 2023: Following the International Day for the Elimination of Sexual Violence in Conflict, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two South Sudanese individuals involved in conflict-related sexual violence (CRSV) in South Sudan. The two individuals designated have abused their positions of political and military authority to carry out acts of sexual violence against citizens of South Sudan. These designations, along with sanctions on ISIS leaders by the U.S. Department of State, represent the first time that a dedicated focus on conflict-related sexual violence —consistent with the Presidential Memorandum signed by President Biden in November 2022 —has led to the imposition of U.S. sanctions.
The following individuals have been added to OFAC's SDN List:
- Al-Matuti, Arkan Ahmad 'Abbas of Iraq and Syria;
- Al-Rashidi, Nawaf Ahmad Alwan of Syria, Turkey, and Iraq;
- Futuyo, Alfred of South Sudan; and
- Nando, James of South Sudan and the Democratic Republic of the Congo.
https://home.treasury.gov/news/press-releases/jy1552 and https://ofac.treasury.gov/recent-actions/20230620
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June 23, 2023: A former member of the United States military was sentenced to 27 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.
Igor Panchernikov, 41, a former Corona, California resident who once served in the United States Air Force Reserves. Panchernikov pleaded guilty on March 24 to one count of conspiracy to violate the Arms Export Control Act. He has been in federal custody since July 2022 after Israel extradited him to the United States. From December 2016 to May 2018, Panchernikov conspired with other individuals to knowingly export from the United States to Russia defense articles without obtaining from the State Department a valid license or other approval for such exports. Panchernikov’s accomplices purchased defense articles – including thermal riflescopes, weapons sights, monoculars, and night vision googles – from various online sellers located in the United States and directed the sellers to mail those items to Panchernikov’s residence in Corona.
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