LATEST EXPORT CONTROLS AND COMPLIANCE UPDATE OCTOBER 2024
This newsletter is a listing of the latest changes in export control regulations through October 31, 2024. 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
President
President Biden Continued the National Emergency with Respect to the Situation in and in Relation to Syria
October 10, 2024: On October 14, 2019, by Executive Order 13894, the President declared a national emergency pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States constituted by the situation in and in relation to Syria.
The situation in and in relation to Syria undermines the campaign to defeat the Islamic State of Iraq and Syria, or ISIS, endangers civilians, and further threatens to undermine the peace, security, and stability in the region, and continues to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared in Executive Order 13894 of October 14, 2019, must continue in effect beyond October 14, 2024. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden continued for 1 year the national emergency declared in Executive Order 13894 with respect to the situation in and in relation to Syria.
https://www.whitehouse.gov/briefing-room/presidential-actions/page/2/
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President Biden Continued the National Emergency with Respect to the Democratic Republic of the Congo
October 11, 2024: On October 27, 2006, by Executive Order 13413, the President declared a national emergency pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) to deal with the unusual and extraordinary threat to the foreign policy of the United States constituted by the situation in or in relation to the Democratic Republic of the Congo, which has been marked by widespread violence and atrocities that continue to threaten regional stability. The President took additional steps to address this national emergency in Executive Order 13671 of July 8, 2014.
The situation in or in relation to the Democratic Republic of the Congo continues to pose an unusual and extraordinary threat to the foreign policy of the United States. For this reason, the national emergency declared in Executive Order 13413 of October 27, 2006, as amended by Executive Order 13671 of July 8, 2014, must continue in effect beyond October 27, 2024. Therefore, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C. 1622(d)), President Biden continued for 1 year the national emergency with respect to the situation in or in relation to the Democratic Republic of the Congo declared in Executive Order 13413, as amended by Executive Order 13671.
https://www.whitehouse.gov/briefing-room/presidential-actions/
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President Biden Continued the National Emergency with Respect to Sudan
October 25, 2024: On November 3, 1997, by Executive Order 13067, the President declared a national emergency with respect to Sudan pursuant to the International Emergency Economic Powers Act (50 U.S.C. 1701 et seq.) and took related steps to deal with the unusual and extraordinary threat to the national security and foreign policy of the United States posed by the actions and policies of the Government of Sudan. On April 26, 2006, by Executive Order 13400, the President determined that the conflict in Sudan’s Darfur region posed an unusual and extraordinary threat to the national security and foreign policy of the United States, expanded the scope of the national emergency declared in Executive Order 13067, and ordered the blocking of property of certain persons connected to the Darfur region. On October 13, 2006, by Executive Order 13412, the President took additional steps with respect to the national emergency declared in Executive Order 13067 and expanded in Executive Order 13400. In Executive Order 13412, the President also took steps to implement the Darfur Peace and Accountability Act of 2006 (Public Law 109-344).
On January 13, 2017, by Executive Order 13761, the President found that positive efforts by the Government of Sudan between July 2016 and January 2017 improved certain conditions that Executive Orders 13067 and 13412 were intended to address. Given these developments, and in order to encourage the Government of Sudan to sustain and enhance these efforts, section 1 of Executive Order 13761 provided that sections 1 and 2 of Executive Order 13067 and the entirety of Executive Order 13412 would be revoked as of July 12, 2017, provided that the criteria in section 12(b) of Executive Order 13761 had been met.
On July 11, 2017, by Executive Order 13804, the President amended Executive Order 13761, extending until October 12, 2017, the effective date in section 1 of Executive Order 13761. On October 12, 2017, pursuant to Executive Order 13761, as amended by Executive Order 13804, sections 1 and 2 of Executive Order 13067 and the entirety of Executive Order 13412 were revoked.
On May 4, 2023, by Executive Order 14098, the President further expanded the scope of the national emergency declared in Executive Order 13067, finding that the situation in Sudan, including the military’s seizure of power in October 2021 and the outbreak of inter-service fighting in April 2023, constituted an unusual and extraordinary threat to the national security and foreign policy of the United States.
The crisis that led to the declaration of a national emergency in Executive Order 13067 of November 3, 1997; the expansion of the scope of that emergency in Executive Order 13400 of April 26, 2006; the taking of additional steps with respect to that emergency in Executive Order 13412 of October 13, 2006, Executive Order 13761 of January 13, 2017, and Executive Order 13804 of July 11, 2017; and the further expansion of the scope of that emergency in Executive Order 14098 of May 4, 2023, has not been resolved. The policies and actions of the Government of Sudan, and the situation in Sudan and Darfur, continue to pose an unusual and extraordinary threat to the national security and foreign policy of the United States. For this reason, the national emergency declared in Executive Order 13067, as expanded by Executive Orders 13400 and 14098, must continue in effect beyond November 3, 2024.
https://www.whitehouse.gov/briefing-room/presidential-actions/
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Department of State, Directorate of Defense Trade Controls (DDTC)
Changes to the International Traffic in Arms Regulations and U.S. Munitions List Categories IV and XV
October 23, 2024: 89 Fed. Reg. 84482: The Department of State published proposed rule to amend the International Traffic in Arms Regulations (ITAR). This rule proposed to amend § 121.0 and § 121.1 of the ITAR and add new exemptions to § 126.8. These proposed changes would revise existing USML definitions, along with USML Categories IV and XV, and certain entries under USML Categories VI, VII, VIII, XI, XIII, and XX. Further, the proposed addition to § 126.8 would create three new licensing exemptions intended to promote U.S. industrial base participation in civil space activity commensurate with national security and foreign policy goals.
With this rule, the Department proposed to amend specific paragraphs within the USML to address controls that were identified as potentially requiring addition, removal, revision, or clarification. The Department proposed the following general types of changes to the ITAR: (1) USML Modernization Efforts, (2) Civil Space-Related License Exemptions and Special Licensing Provisions, and (3) USML Category Revisions.
USML Modernization Efforts:
The Department is modernizing the USML, specifically to improve its usability, clarity, and consistency in structure and regulatory text. This proposed rule contains revisions to that effect in the following areas:
- Revision and Removal of Notes and Expansion of § 121.0 Definitions;
- Removal of Specially Designed as a Criterion in Certain Paragraphs;
- Consistency in Construction; and
- Clarification of Internal References and Standardization of Regulatory Text tructure of USML Categories.
Civil Space-Related License Exemptions and Special Licensing Provisions:
The Department proposed to add to part 126 three new licensing exemptions intended to promote U.S. industrial base participation in civil space activity commensurate with its national security and foreign policy goals. The Department further proposed to codify a fourth licensing exemption currently provided as guidance in an existing note within the USML.
Official Space Agency Exemption
This license exemption, proposed to be in a new § 126.8(a), would authorize certain transfers of defense articles and defense services when conducted entirely within the scope of an official U.S. government agency space program listed in § 126.8(a)(2). While the proposed list of articles and services subject to the exemption applies to several NASA spacecraft, the Department emphasizes this licensing exemption does not similarly apply to the space launch vehicles for these spacecraft. The Department assesses the underlying launch vehicle technology is independent of the spacecraft that potentially warrant a licensing exemption, in part due to the implicitly civil, multilateral, or scientific mission of these specific spacecraft.
Space Activity Exemption
This exemption, proposed to be in a new § 126.8(b), consists of four provisions. The first would authorize certain transfers of defense articles and § 120.32(a)(2) defense services supporting space launches. Certain transfers of electrical connectors would be eligible for this exemption, as the Department assesses that, while they continue to warrant regulation by this subchapter, certain transfers of these articles may be conducted under a licensing exemption without risk to U.S. national security and foreign policy interests.
The Department requested public comment on additional space technologies having both military and commercial applications that should be considered for incorporation into this exemption. Comments on the benefit of such an expansion of the exemption to the regulated community and any perceived or recommended proliferation risk mitigations are also requested.
The second provision would authorize certain services related to the transmission of space launch vehicle telemetry, to improve safety of flight and support the growing space launch industry. The Department proposed to limit this authorization to space launch vehicles since similar data can be used by rockets and missiles to deliver weapons of mass destruction.
The third provision would authorize certain services to support collaboration with foreign persons when on-orbit defense articles are utilized in support of fundamental research, as defined in § 120.34(a)(8).
The fourth provision would authorize certain services associated with radiofrequency transmissions using on-orbit defense articles, including geolocating certain automated information broadcasts, emergency transmissions, and cellular transmissions.
Space Tourism and Research Exemption
This exemption, proposed to be in a new § 126.8(c), would authorize certain transfers of manned spacecraft for space tourism or in support of fundamental research, as defined in § 120.34(a)(8).
The Department noted the proposed research exemptions apply specifically to certain basic and applied research, and not to the engineering development phase of research and development. Similarly, they do not apply to the design and development of a defense article or to research either not intended for publication or subject to publication restrictions or non-disclosure agreements.
Special Licensing Provision for Defense Articles Incorporated Into Spacecraft Subject to the EAR
This exemption, proposed to be in a new § 126.8(d), would authorize certain transfers of defense articles while they are incorporated into spacecraft subject to the EAR. This is consistent with two current notes (note 2 to paragraph (e) and note 2 to paragraph (e)(17)) the Department proposed to remove from Category XV.
Satellite Signature Reduction
In addition to the proposed exemptions previously described, the Department also requests public comment on specific regulatory changes or clarifications to facilitate industry efforts to reduce the apparent magnitude, as viewed from Earth, of satellite brightness. Commenters should be cognizant of the Department’s continued need to control signature reduction technologies that provide a critical military or intelligence advantage, including technologies to reduce spacecraft signatures as viewed in, or between, orbits.
USML Category Revisions:
USML Category IV
The Department proposed to update the title of Category IV to better reflect the items described therein and to avoid the potential misinterpretation that the list of items in the title is exhaustive.
Paragraphs (a)(1) and (2)
The Department proposed minor adjustments to USML Category IV(a)(1) and (2) for consistency in construction of the control text.
The proposed changes to USML Category IV relate to the controls on the following items:
- Man-Portable Air Defense Systems (MANPADS);
- Anti-Tank Missiles;
- Rockets;
- Bombs;
- Mines;
- Grenades;
- Loitering Munitions;
- Kinetic Kill Vehicles;
- Post-Boost Vehicles;
- Hypersonic Glide Vehicles;
- Re-Entry Vehicles;
- Range and Payload;
- Model Rockets;
- Launch Platforms;
- Propulsion Systems;
- Rocket Stages, Motors, and Engines;
- Air-Breathing Engines and Pressure Gain Combustion-Based Propulsion Systems;
- Flight Control Systems, Guidance Systems, and Attitude Control Equipment;
- Thrust Vector Control Systems;
- Thermal Protection Systems (g., Heat Shields and Heat Sinks);
- Self-Destruct Systems;
- Separation Systems;
- SAFF Components;
- Seeker Systems;
- Test Equipment; and
- Non-Nuclear Warheads.
Changes to USML Category IV(c): The Department notes it will address issues related USML Category IV(c) in a separate rulemaking. However, the Department still welcomes comments related to this paragraph.
Changes to USML Category IV(h):
The Department proposed to modify USML Category IV(h) to economize the text of its subordinate paragraphs. Currently, some subordinate paragraphs of (h) require an article be used in an end item described elsewhere in Category IV. The Department proposed to clearly stipulate in paragraph (h) that the articles in its subordinate paragraphs are for end-items described elsewhere in Category IV, thereby eliminating the need to repeat that requirement in each of its subordinate paragraphs. Consistent with its intent to move systems from paragraph (h) to paragraph (e), the Department also proposed to delete the reference to systems and subsystems in paragraph (h).
The proposed changes to USML Category IV(h) relate to the controls on the following items:
- Grip Stocks for MANPADS;
- Nozzles, Nozzle Throats, Nose Tips, Nose Fairings, and Aerospikes;
- Engine or Motor Mounts;
- Combustion Chambers;
- Injectors;
- Penetration Aids;
- Motor Cases;
- Liners and Insulation;
- Radomes, Sensor Windows, Antenna Windows, and Embedded Antennae;
- Payload Fairings;
- Launch Canisters;
- Fuzes;
- Propellant Tanks and Altimeters;
- Umbilical and Interstage Electrical Connectors; and
- Turbo Pumps.
USML Category IV(i) Technical Data and Defense Services: The Department proposed minor modifications to USML Category IV(i) for consistency in construction of the control text.
USML Category VI, VII, VIII, and XX Conforming Changes:
The Department proposed to modify USML Category VI(f)(6) and (7) to avoid overlap in controls between those paragraphs and the proposed revision and intent of Category IV(b). As such, the Department proposed to clarify these paragraphs only describe certain integration equipment, aircraft launch and recovery equipment, and certain shipborne defensive systems, not articles described in Category IV(b). The Department further proposed to split paragraph (f)(6) into three subordinate paragraphs for ease of parsing and adjust the “MT” designations for consistency with the MTCR Annex.
Similarly, the Department proposed to modify USML Category VII(g)(2) to avoid overlap in controls between that paragraph and the proposed revision and intent of Category IV(b), and therefore proposed to clarify paragraph (g)(2) only describes articles not already described in Category IV(b).
The Department proposed to add USML Category VII(g)(15) and modify USML Category VIII(h)(6) to ensure items designed for integrating certain defense articles are described in the same USML category as the platform they are being integrated into and to avoid ambiguity about whether they are controlled in USML Category IV(b).
Subsequent to these changes, these paragraphs will only describe articles that assist in the integration between a vehicle and either a launching system or a self-launching munition.
The Department also proposed minor changes to USML Categories: XI; XII; and XIII. (refer to link at end of article)
USML Category XV
The proposed changes to USML Category XV relate to the controls on the following items:
- Spacecraft;
- Detection or Mitigation of a Nuclear Detonation;
- Detect and Track Objects;
- Spacecraft for Signals Intelligence;
- Constellations;
- Space-Based Weapons;
- Spacecraft With Remote Sensing Capabilities;
- Radar Remote Sensing;
- Position, Navigation, and Timing;
- Autonomous Collision Avoidance;
- Suborbital Craft;
- Inspection or Surveillance;
- Classified Spacecraft;
- Articles Jettisoned From Another Spacecraft;
- Ground Control Systems;
- Movement of Systems;
- Active Cooling Systems;
- Vibration Suppression Systems;
- Attitude Determination and Control Systems;
- Thermal Protection Systems (g., Heat Shields and Heat Sinks);
- Spacecraft Propulsion;
- Spacecraft Parts, Components, Accessories, and Attachments;
- Antennas;
- Optics;
- Focal Plane Arrays;
- Optical Bench Assemblies;
- Directed Energy Systems;
- Control Moment Gyroscopes;
- Monolithic Microwave Integrated Circuits (MMICs);
- Oscillators for Radar;
- Star Trackers;
- Primary, Secondary, or Hosted Payloads; and
- Payloads Developed with Department of Defense Funding.
The Department proposed the following additions to USML Category XV:
- The Department proposed to add paragraphs (a)(14) through (16). These paragraphs designate, respectively, spacecraft capable of non-cooperative grappling or docking, in-orbit construction of other defense articles, and deploying multiple spacecraft into different orbits.
- The technology required to facilitate non-cooperative docking is likely to be used in an adversarial manner. A spacecraft capable of in-orbit construction of other defense articles represents a critical logistical advantage. And spacecraft that can rapidly deploy multiple spacecraft into multiple different orbits provide a critical military or intelligence advantage when compared to commercial systems that may be able to achieve the same result over a much longer timeframe.
- Addition of USML Category XV(e)(22). The Department proposed to add a new paragraph at USML Category XV(e)(22) for technologies that facilitate the signature reduction of in-orbit spacecraft observations. The proposed regulatory text reflects the Department’s intent to exclude technology used only to minimize light pollution, as seen from the ground.
- Notes USML Category XV(e): The Department proposed to eliminate note 1 to USML Category XV(e), as the jurisdiction of articles not described in paragraph (e) is already addressed in the order of review at § 120.11. Note 2 to paragraph (e) delegates the licensing of articles described in paragraph (e) when integrated into a spacecraft subject to the EAR. The Department proposed a licensing exemption in § 126.8 to codify this exemption and to facilitate the deletion of note 2. The Department also proposed to delete notes 3 and 4 to paragraph (e), as the proposed revisions to USML Category XV remove all but one reference to space-qualified and the Department assesses notes 3 and 4 are no longer required to identify space-qualified atomic clocks.
USML Category XV(f) Technical Data and Defense Services:
The Department proposed to modify USML Category XV(f) by incorporating guidance currently provided in notes 1 through 3 to paragraph (f), which is not already included in the definition of technical data at § 120.33 or the proposed definition of “spacecraft housekeeping data and output at § 121.0.” The Department also proposed to delete the explanatory information regarding defense services found in the control text, as it assesses such information does not provide substantial guidance beyond the order of review provided at § 120.11 and the USML text, and similar redundancy is not provided in other USML Categories.
Please see the federal register notice below for the complete proposed revisions to ITAR and USML Categories IV and XV.
https://www.pmddtc.state.gov/ddtc_public/ddtc_public?id=ddtc_public_portal_news_and_events
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DDTC Name And Address Changes Posted To Website
October 7 through 31, 2024: The Directorate of Defense Trade Controls (DDTC) posted the following name and/or address changes on its website at
- Name change of Eurocopter Kazkahstan Engineering LLP to Airbus Helicopters Kazakhstan Engineering due to merger;
- Name change of Celemetrix Australia Pty Ltd to Trescal Australia Pty Ltd due to merger;
- Name change of Delom Services Inc. to Wajax Limited due to corporate rebranding;
- Name change of Bayanat AI PLC and AI Yah Satellite Communications Company PJSC to Space42 PLC due to merger;
- Name change of WESCO Integrated Supply Polska Sp. z. o. o. to Vallen Integrated Supply Polska Sp z. o.o. due to merger.
- Address change of ALTEN LTD from 41 Moorgate, London EC2 R6PP, United Kingdom to Saffron House, 6-10 Kirby Street, London EC1N 8TS, United Kingdom.
- Address change of Filial af GE Aviation Systems North America LLC’s Denmark operations from Osterfaelled Torv 3, Copenhagen 2100, Denmark to Frederiksborggade 15, 3 Copenhagen 1358, Denmark.
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Department of Defense, Defense Security Cooperation Agency (DSCA)
DSCA Notifies Congress of Potential FMS Sale To India
October 7, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of India has requested to buy fifty-three (53) MK 54 MOD 0 Lightweight Torpedo all up rounds. The following non-MDE items will also be included: Recoverable Exercise Torpedoes (REXTORP); air launch accessories; classified and unclassified torpedo spare parts; torpedo containers; torpedo support equipment, including test equipment and tools; torpedo support services; classified and unclassified books and other publications; other technical assistance, including technical support, technical program management, infrastructure support, test equipment sustainment, exercise firing assistance, contract management, and initial follow-on-technical support (FOTS); in-country torpedo training; related equipment and services; and other related elements of logistics and program support. The estimated total cost is $175 million.
https://www.dsca.mil/press-media/major-arms-sales/india-mk-54-mod-0-lightweight-torpedoes
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DSCA Notifies Congress of Potential FMS Sale To Italy
October 7, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Italy has requested to buy the Electronic Attack (EA)-37B mission system, consisting of the following non-Major Defense Equipment: Network Centric Collaborative Targeting (NCCT) systems; System Control and Monitoring subsystems; Radio Frequency Receiver (RFR) subsystems; Software-defined Radio (SDR) subsystems; Counter Radar Assembly; Array Panels; AN/ARC-210 RT-2036 radios; KG-250 In-line Network Encryptors; KY-100 Narrow/wideband Terminals; KIV-77 Mode 4/5 Identification Friend or Foe (IFF); AN/PYQ-10C Simple Key Loaders; integration and test support and equipment; aircraft support and support equipment; secure communications equipment, precision navigation, and cryptographic devices; major and minor modifications, maintenance, and maintenance support; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; facilities and construction support; transportation and airlift support; warranties; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $680 million. The principal contractor will be BAE Systems, located in Hudson, NH. The U.S. government is not aware of any offset agreements in connection with this potential sale
https://www.dsca.mil/press-media/major-arms-sales/italy-electronic-attack-mission-system
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DSCA Notifies Congress of Potential FMS Sale To Romania
October 7, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Romania has requested to buy four (4) AN/MPQ-64 F1 Sentinel radar systems. The following non-MDE items will also be included: IPS 250X High Assurance Internet Protocol Encryptors (HAIPE); KIV-77 Identification Friend-or-Foe (IFF) crypto appliqué with Mode 5 and Mode S capability; AN/PSN-13 Defense Advanced Global Positioning System (GPS) Receivers (DAGR) with Selective Availability Anti-Spoofing Module (SAASM); AN/PYQ-10 Simple Key Loaders (SKL); support equipment; spare and repair parts, consumables, accessories and repair and return support; classified software; classified command and control (C2) systems and communications and data supply systems; prime movers; new equipment training; weapon system support and test equipment; publications and technical documentation; personnel training and training equipment; classified software; classified books and publications; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $110 million. The principal contractor will be RTX Corporation, located in Andover, MA. There are no known offset agreements in connection with this potential sale.
https://www.dsca.mil/press-media/major-arms-sales/romania-sentinel-radar-systems
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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia
October 11, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy two thousand five hundred three (2,503) AGM-114R3 Hellfire II missiles (3 for lot acceptance testing). Also included are support and test equipment; integration and test support; spare and repair parts; software delivery and support; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical and logistics support services; storage; and other related elements of logistical and program support. The total estimated cost is $655 million. The principal contractor will be The Lockheed Martin Corporation, Troy, AL. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia
October 11, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy ten thousand (10,000) M456 series, 105mm, High Explosive Anti-Tank Tracer cartridges. Also included are various types of tanks, howitzer, and machine gun ammunition; propelling charges; fuses; primers; grenades; support and test equipment; integration and test support; spare and repair parts; software delivery and support; publications and technical documentation; personnel training and training equipment; U.S. Government and contractor engineering, technical and logistics support services; storage; and other related elements of logistical and program support. The total estimated cost is $139 million. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Saudi Arabia.
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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia
October 11, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy two-hundred twenty (220) AIM-9X Block II Sidewinder Tactical Missiles. Also included are missile containers; support equipment; spares; missile software; training; and U.S. Government and contractor technical assistance; and other related elements of logistics and program support. The estimated total cost is $251.8 million. The principal contractor will be RTX Corporation, located in Arlington, VA. There are no known offset agreements proposed in connection with this potential sale.
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DSCA Notifies Congress of Potential FMS Sale To United Arab Emirates
October 11, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of the United Arab Emirates has requested to buy two hundred fifty-nine (259) Guided Multiple Launch Rocket System (GMLRS) M31A1 Unitary Pods (1,554 missiles at six missiles per pod) and two hundred three (203) Army Tactical Missile Systems (ATACMS) M57 Unitary Missiles. Also included are publications; personnel training and training equipment; software development; U.S. Government and contractor engineering, technical and logistics support services; and other related elements of logistical and program support. The estimated total cost is $1.2 billion. The principal contractor will be Lockheed Martin, Grand Prairie, TX. There are no known offset agreements proposed in connection with this potential sale. Implementation of this proposed sale will require the temporary assignment of four (4) U.S. Government and four (4) U.S. contractor representatives to the United Arab Emirates for a duration of no longer than ten (10) days to support new software equipment training and the stockpile reliability program.
https://www.dsca.mil/press-media/major-arms-sales/united-arab-emirates-gmlrs-and-atacms-munitions
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DSCA Notifies Congress of Potential FMS Sale To The Netherlands
October 16, 2024: : The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government the Netherlands has requested to buy the following non-Major Defense Equipment items: AN/PRC-117G radios; AN/PRC-152A radios; AN/PRC-160 radios; AN/PRC-163 radios; AN/PRC-167 radios; tactical key loaders; network encryptors; Government and contractor technical assistance; spares; and other related elements of logistics and program support. The estimated total cost is $1.42 billion. The principal contractor will be L3Harris Global Communications, Inc., located in Rochester, NY. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the principal contractor. Products and services of TrellisWare Technologies, Inc., located in San Diego, CA, and ViaSat, Inc., located in Carlsbad, CA are included in the Foreign Military Sale.
https://www.dsca.mil/press-media/major-arms-sales/netherlands-radio-equipment
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DSCA Notifies Congress of Potential FMS Sale To Japan
October 18, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government Japan has requested to buy up to two hundred twelve (212) Rolling Airframe Missiles (RAM) Block 2B, RIM-116E. The following non-MDE items will also be included: RAM Guided Missiles Round Pack (GMRP); Tri-Pack shipping and storage containers; training equipment; operator manuals and technical documentation; U.S. Government and contractor engineering, technical, and logistics support and assistance; support for establishment of an Intermediate Level Maintenance Facility (ILMF); and other related elements of logistics and program support. The estimated total cost is $360 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. There are no known offset agreements proposed in connection with this potential sale.
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DSCA Notifies Congress of Potential FMS Sale To Poland
October 23, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Poland has requested to buy fifty-eight (58) Improved Programmable Display Generators (48 installed, 10 spares); three (3) AGM-158 Joint Air-to-Surface Standoff Missile (JASSM) Flight Test Vehicles, Captive Carry; three (3) Small Diameter Bomb II (SDB II), GBU53/B Guided Test Vehicles (GTV); eight (8) SDB II, GBU-53/B Captive Carry Reliability Trainers; two (2) SDB I, GBU-39(T-1)/B Guided Test Vehicles (GTV); fifty-eight (58) Embedded Global Positioning System (GPS) Inertial Navigation Systems (INS) (EGI) with Selective Availability Anti-Spoofing Module (SAASM) or M-Code capability and Precise Positioning Service (PPS) (48 installed, 10 spares); fifty-eight (58) AN/APG-83 Active Electronically Scanned Array (AESA) Scalable Agile Beam Radars (SABR) (48 installed, 10 spares); sixty (60) Modular Mission Computer (MMC) 7000AH upgrades, or equivalent (48 installed, 12 spares); sixty (60) Next Generation Mission Computer (XMC), or next generation equivalent (48 installed, 12 spares); seventy-three (73) AN/ALQ-257 Integrated Viper Electronic Warfare Suites (IVEWS), or seventy-three (73) AN/ALQ-254V(1) Viper Shield advanced electronic warfare (EW) suites, or equivalent (63 installed, 10 spares); two (2) AIM-9X Block II Sidewinder Special Air Training Missiles; and two (2) AIM-9X Block II Sidewinder Captive Air Training Missiles (CATM). The following non-MDE items will also be included: major modifications and maintenance equipment; Phased Array Warning System (PAWS-2) missile warning systems; Joint Helmet Mounted Cueing Systems (JHMCS II); AN/ARC-238 radios (or equivalent); AN/APX-126/127 Advanced Identification Friend or Foe (AIFF) with combined interrogator/transponder (CIT) and Mode 5 (or equivalent); AN/ALE-47 Countermeasure Dispenser Systems (CMDS), classified countermeasure processors, sequencer switching units, and control display units; AN/ALQ-254V(1) Viper Shield advanced EW suites, including lab assets (or equivalent); KY-58, KIV-78, or equivalent, KGV-135A, AN/PYQ-10 Simple Key Loaders (SKLs), MS-110 reconnaissance pods, communications security (COMSEC) cables, and cryptographic devices; tactical synthetic aperture radars; Joint Mission Planning Systems (JMPS) with unique planning components and software; AGM-158 JASSM classified test equipment; aircraft components, parts, and accessories; spare parts, accessories and consumables, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $7.30 billion. The principal contractor will be Lockheed Martin, located in Greenville, SC. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/press-media/major-arms-sales/poland-f-16-viper-midlife-upgrade
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DSCA Notifies Congress of Potential FMS Sale To Saudi Arabia
October 24, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Kingdom of Saudi Arabia has requested to buy five hundred seven (507) tube-launched, optically-tracked, wireless-guided (TOW) 2A, radio frequency (RF) missiles (BGM-71E-4B-RF) (including 7 “fly-to-buy” missiles); and five hundred seven (507) TOW 2B, RF missiles (BGM-71F-3-RF) (including 7 “fly-to-buy” missiles). The following non-MDE is also included: support and test equipment; simulators; generators; integration and test support; spare and repair parts; communications equipment; software delivery and support; facilities and construction support; publications and technical documentation; personnel training and training equipment; support equipment; U.S. Government and contractor engineering, technical, and logistics support services; studies and surveys; and other related elements of logistics and program support. The estimated total cost is $440 million. The principal contractor will be RTX Corporation located in Tucson, AZ. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/press-media/major-arms-sales/kingdom-saudi-arabia-tow-2a-tow-2b-missiles
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DSCA Notifies Congress of Potential FMS Sale To Japan
October 25, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Japan has requested to buy up to two (2) BQM-177A Subsonic Sea-Skimming Aerial Targets (SSAT) for Aegis System Equipped Vessels (ASEV). The following non-MDE items will also be included: GQM-163 target drones; follow-on technical support for ASEVs, including for Combat Systems Sea Qualification Trials (CSSQT) and sustainment support services; Aegis computer software updates; combat systems integration; system integration, testing, overhauls, and upgrades; development, familiarization, operational, and maintenance support; classified books and other publications (technical and non-technical); adaption data; annual service agreements; test support; technical documentation; personnel training; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $113 million. The principal contractor for the BQM-177A SSATs will be Kratos Defense, located in Sacramento, CA, and Fort Walton Beach, FL. The principal contractor for the GQM-163A target drones will be Northrop Grumman, located in Chandler, AZ. The principal contractor for the Aegis Weapon System (AWS) will be Lockheed Martin Corporation, located in Moorestown, NJ. There are no known offset agreements proposed in connection with this potential sale.
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DSCA Notifies Congress of Potential FMS Sale To Taipei Economic and Cultural Representative Office
October 25, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Taipei Economic and Cultural Representative Office in the United States has requested to buy three (3) National Advanced Surface-to-Air Missile System (NASAMS) medium-range air defense solutions, that include: three (3) AN/MPQ-64F1 Sentinel radar systems; one hundred twenty-three (123) Advanced Medium-Range Air-to-Air Missiles-Extended Range (AMRAAM-ER); two (2) AMRAAM-C8 guidance sections; and four (4) Multifunctional Information Distribution Systems (MIDS). Also included are fire distribution centers (FDC); Canister Launcher Systems (CLS); electro-optical/infrared (EO/IR) systems; Tactical Control Center (TCC) systems; FDC indoor training simulator; radar communication nodes; MIDS Link 16-capable radios; IPS 250X High Assurance Internet Protocol Encryptions (HAIPE); KIV-77 Identification Friend-or-Foe (IFF) Crypto Applique; AN/PSN-13 Defense Advanced Global Positioning System (GPS) receivers (DAGR) with Selective Availability Anti-Spoofing Module (SAASM); AN/PYQ-10 Simple Key Loaders (SKL), code loaders and cable sets; AIM-120 control sections and containers; AMRAAM and AMRAAM-ER Captive Air Training Missiles (CATMs); AIM-120ER load trainers; weapon system support and support equipment; spare parts, consumables, accessories and repair and return support; classified software; classified and unclassified publications and technical documentation; studies and surveys; U.S. Government and contractor technical support, engineering and logistics support services; warranty services; Systems Integration and Checkout (SICO); and other related elements of logistics and program support. The total estimated cost is $1.16 billion. The principal contractor will be Raytheon, located in Andover, MA. There are no known offset agreements proposed in connection with this potential sale.
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DSCA Notifies Congress of Potential FMS Sale To Taipei Economic and Cultural Representative Office
October 25, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Taipei Economic and Cultural Representative Office in the United States has requested to buy AN/TPS-77 and AN/TPS-78 radar turnkey systems; spare and repair parts, consumables and accessories; repair and return support; transportation support; personnel training and training equipment; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The total estimated cost is $828 million. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to the recipient.
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DSCA Notifies Congress of Potential FMS Sale To Switzerland
October 28, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Switzerland has requested to buy sustainment support for its five (5) PATRIOT Fire Units and missile inventory. The following non-MDE items will be included: general electronic test station equipment and program sets; Foreign Liaison Officer support; international engineering services; Field Surveillance Program; modification and upgrade kits; unclassified and classified repair and return; classified missile processing; unclassified and classified spares; transportation; publications and technical documentation; training; U.S. Government and contractor technical, engineering, and logistics support services; and other related elements of logistics and program support. The total estimated cost is $450 million. The prime contractors will be RTX Corporation, located in Tewksbury, MA; Lockheed Martin, located in Dallas, TX; and Leidos, located in Huntsville, AL. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
https://www.dsca.mil/press-media/major-arms-sales/switzerland-patriot-sustainment
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DSCA Notifies Congress of Potential FMS Sale To Denmark
October 29, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Denmark has requested to buy up to two hundred three (203) AIM-120D-3 Advanced Medium Range Air-to-Air Missiles (AMRAAM); and up to nine (9) AIM-120D-3 AMRAAM guidance sections to include precise position provided by either Selective Availability Anti-Spoofing Module or M-Code. The following non-MDE items will also be included: spare AMRAAM control sections; missile containers and support equipment; munitions support and support equipment; spare parts, consumables and accessories, and repair and return support; weapons software and support equipment; classified software delivery and support; classified publications and technical documentation; transportation support; studies and surveys; U.S. Government and contractor engineering, technical and logistics support services; and other related elements of logistics and program support. The estimated total cost is $744 million. The principal contractor will be RTX Corporation, located in Tucson, AZ. The purchaser typically requests offsets. Any offset agreement will be defined in negotiations between the purchaser and the contractor.
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DSCA Notifies Congress of Potential FMS Sale To Argentina
October 30, 2024: The U.S. Department of Defense’s Defense Security Cooperation Agency (DSCA) notified Congress that The Government of Argentina has requested to buy equipment and services to support twenty-four (24) F-16 Block 10/15 aircraft procured through third-party transfer. These items include: thirty-six (36) AIM-120 C-8 Advanced Medium Range Air-to-Air Missiles (AMRAAM); two (2) AIM-120 C-8 AMRAAM guidance sections; one hundred two (102) MK-82 500lb general purpose bombs; fifty (50) MXU-650 air foil groups for 500lb GBU-12 Paveway II laser-guided bombs; one hundred two (102) FMU-152A/B joint programmable fuzes with FZU-63A/B fuze systems; and fifty (50) computer control groups MAU-169L/B. The following non-MDE items will also be included: weapons and weapons support equipment; explosive charges, devices, propellants, and components; AN/ARC-238 radios; Joint Mission Planning Systems (JMPS); FMU-169D/B inert fuzes; Ground Support System (GSS) for Link-16; KY-58M and KIV-78 cryptographic devices, AN/PYQ-10 Simple Key Loaders (SKL), communications security (COMSEC) cables, and other COMSEC devices and equipment; cartridges, chaffs, and flares; practical explosive ordinance disposal system trainer; avionics support; communications equipment; precision navigation; Computer Program Identification Numbers (CPINS); electronic warfare database support; major and minor modifications and maintenance support; aircraft components, parts, and accessories; instruments and lab equipment; spare parts, consumables and accessories, and repair and return support; classified and unclassified software delivery and support; classified and unclassified publications and technical documentation; personnel training and training equipment; clothing, textiles, and individual equipment; jet fuel; aircraft ferry, aerial refueling, and transportation support; studies and surveys; U.S. Government and contractor engineering, technical, and logistics support services; and other related elements of logistics and program support. The estimated total cost is $941 million. The principal contractor will be Lockheed Martin, located in Fort Worth, TX. There are no known offsets proposed in connection with this potential sale. Implementation of this proposed sale will not require the assignment of any additional U.S. Government or contractor representatives to Argentina.
https://www.dsca.mil/press-media/major-arms-sales/argentina-f-16-aircraft-equipment-and-support
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Department of Commerce – Bureau of Industry and Security (BIS)
BIS Updates Boycott Requester List
October 1, 2024: The Department of Commerce’s Bureau of Industry and Security (BIS) published its second quarterly update of the boycott Requester List. This list notifies companies, financial institutions, freight forwarders, individuals, and other U.S. persons of potential sources of certain boycott-related requests they may receive during the regular course of business. A party’s inclusion on the Requester List does not mean that U.S. persons are restricted from dealing with the listed party; a party’s inclusion does mean that U.S. persons are on notice that the listed party is more likely to make reportable boycott-related requests. The updated public list of entities who have been identified as having made a boycott-related request in reports received by BIS includes a total of 36 additions. BIS has also removed 21 entities.
https://www.bis.gov/press-release/bis-updates-boycott-requester-list-0
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Expansion of Validated End User Authorization: Data Center Validated End User Authorization
October 2, 2024: 89. Fed. Reg. 80080: The Department of Commerce, Bureau of Industry and Security (BIS), amended the Export Administration Regulations (EAR) to expand the Validated End User Authorization (VEU) program to include VEU Authorization for data centers located in specified destinations (“Data Center VEU” or “Data Center VEU Authorization”). This expansion of the VEU program to include Data Center VEU is intended to facilitate quick and reliable export or reexport of items on the Commerce Control List necessary for a data center, including advanced computing items, to preapproved trusted end users. Data Center VEU adopts much of the framework of the existing VEU program, with additional requirements. This expansion of eligibility is intended to update the VEU program to recognize the advancement and benefits of artificial intelligence. As under the original VEU Authorization Program, the U.S. government will rigorously review Data Center VEU candidates’ applications subject to detailed and verifiable criteria.
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BIS Issues Guidance to Financial Institutions on Best Practices for Compliance with the Export Administration Regulations
October 9, 2024: The Department of Commerce’s Bureau of Industry and Security (BIS) published guidance for financial institutions (FIs) concerning best practice recommendations for complying with the Export Administration Regulations (EAR).
The guidance provides both background information on the EAR and recommendations for steps financial institutions can take to minimize the likelihood of EAR violations. The recommendations include a description of EAR-related due diligence best practices, the encouragement of ongoing transaction reviews for red flags, and a delineation of which types of real-time transaction screenings are and are not regarded as a best practice.
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Effectiveness of Licensing Procedures for the Export and Reexport of Agricultural Commodities to Cuba
October 16, 2024: 89 Fed. Reg. 8356: The Bureau of Industry and Security (BIS) is requesting public comments on the effectiveness of its licensing procedures as defined in the Export Administration Regulations (EAR) for the export and reexport of agricultural commodities to Cuba. BIS will include a description of any comments it receives in its biennial report to Congress, as required by the Trade Sanctions Reform and Export Enhancement Act of 2000, as amended (TSRA).
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Commerce Announces Series of Rules to Modernize Space-Related Export Controls
October 17, 2024: The Commerce Department’s Bureau of Industry and Security (BIS) released three rules—one Final Rule, one Interim Final Rule, and one Proposed Rule—to modernize BIS’s space-related export controls. These updated controls will further U.S. innovation and technology leadership while protecting U.S. national security and foreign policy interests.
This action is the result of an extensive review—directed by the National Space Council, which is led by Vice President Kamala Harris—to enable a globally competitive U.S. space industrial base, while strengthening U.S. international space partnerships. These updates reflect the Biden-Harris Administration’s commitment to maintaining U.S. leadership in space, protecting our national security, and strengthening our foreign alliances.
The series of regulatory changes modernizing space-related export controls consists of the following rules:
- 89 Fed. Reg. 84766: In a Final Rule, BIS is removing license requirements for exports of certain items involving remote sensing or space-based logistics, assembly, or servicing spacecraft destined for Australia, Canada, and the United Kingdom. This rule deepens the United States’ commitment to some of its closest allies, furthering our collective security, reducing unnecessary export control restrictions, and ensuring secure trade.
- 89 Fed. Reg. 84770: In an Interim Final Rule, BIS is removing license requirements for exports of certain spacecraft components to over 40 allies and partners worldwide, reducing licensing requirements for the least sensitive components for most destinations, and broadening license exceptions to support additional National Aeronautics and Space Administration (NASA) cooperative programs. These changes advance international cooperation and bolster America’s global leadership in space technology.
- 89 Fed. Reg. 84784: Additionally, in a Proposed Rule published in concert with the Department of State, BIS outlines initial proposals to transfer jurisdiction of certain space-related defense articles that no longer provide a critical military or intelligence advantage from the U.S. Munitions List (USML) maintained by the Department of State to the Commerce Control List. Examples include spacecraft capable of refueling other spacecraft and spacecraft capable of autonomous collision avoidance. This proposed transfer would enable the use of BIS license exceptions that facilitate exports of commercial space items to close allies and partners. BIS welcomes public comment from all interested parties on this Proposed Rule within 30 days of publication.
These actions mark a pivotal step in updating and modernizing the U.S. Government’s space-related export controls and enhancing international partnerships while continuing to deny critical technologies to our adversaries.
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U.S. Census Bureau
October 17, 2024:
Tips on How to Resolve AES Response Messages
When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. Though the shipment is accepted, the filer may still receive a Verify Message, Compliance Alert, Informational Message or Warning Message along with their ITN. However, if the shipment is rejected, a Fatal Error notification is received and must be corrected to receive a valid ITN.
To help you take the appropriate action for the different AES Response Messages, here are some tips on how to address the most frequent messages that were generated in AES for this month.
Response Code: 105
Narrative: Mode of Transportation Unknown
Severity: Fatal
Reason: The Mode of Transportation Code reported is not valid in AES.
Resolution: The Mode of Transportation Code reported must be one recognized in AES and listed in the ‘Appendix T – Mode of Transportation Codes’.
Verify the Mode of Transportation Code, correct the shipment and resubmit.
Response Code: 147
Narrative: Routed Export Indicator Missing
Severity: Fatal
Reason: The Routed Export Indicator is missing.
Resolution: A routed export transaction is a transaction in which the Foreign Principal Party in Interest (FPPI) authorizes a U.S. agent to facilitate the export of items from the United States and to prepare and file Electronic Export Information (EEI). You must report the Routed Export Indicator as Yes or No.
Verify whether or not this is a routed export transaction, correct the shipment and resubmit.
It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture but not later than five calendar days after departure.
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October 21, 2024:
Port of Unlading Codes Updated in the Automated Export System (AES)
October 21, 2024
Please note the following Port of Unlading Code Name has been UPDATED in the AES effective immediately.
Port Name Port Code Country
Whannock, BC 12488 Canada
The following Port of Unlading Codes have been ADDED to the AES effective immediately.
Port Name Port Code Country
| Tolu | 30111 | Columbia |
| Krishnapatnam | 53356 | India |
| Nghi Son | 55203 | Vietnam |
| Phu My | 55209 | Vietnam |
| Nghe Tinh | 55210 | Vietnam |
| Morowali | 56029 | Indonesia |
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Foreign Trade Regulations (FTR): Clarification of Filing Requirements Regarding In-Transit Shipments and Other FTR Provisions
October 31, 2024: 89. Fed. Reg. 86762: The Bureau of the Census (Census Bureau) proposed to amend its regulations to clarify the requirements governing in-transit shipments from foreign countries through the United States that are subsequently exported to a foreign destination. This rulemaking proposed to clarify who is the U.S. Principal Party in Interest (USPPI) and revise the entry number description when goods are entered into the United States for consumption or warehousing, and then stored in a warehouse or storage facility or admitted into a Foreign Trade Zone (FTZ) before being exported. This rule also proposed to clarify that when a customs broker is the USPPI and they are requested to provide information from the customs entry for the filing of the Electronic Export Information (EEI), that they obtain consent from their client, as required in the customs regulations. Additionally, this proposed rule revises several sections, including definitions, mandatory filing requirements, responsibilities of parties to the export transaction, confidentiality, penalties, and voluntary self-disclosures to ensure clarity, accuracy, and consistency throughout the FTR.
| LATEST SANCTIONS FINES & PENALTIES |
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.
Fines and Penalties
Violations of the Arms Export Control Act and the International Traffic in Arms Regulations by Precision Castparts Corp.
October 7, 2024: Precision Castparts Corp. (“Precision”) entered into a three-year Consent Agreement to settle allegations that it violated the International Traffic in Arms Regulations (ITAR) in connection with twenty-four export violations involving unauthorized exports of Technical Data to Foreign-Person Employees (FPEs). All the violations were Voluntarily Disclosed to the Department of State by Precision in 2019 Precision agreed to pay a fine of three million ($3,000,000) of which one million ($100,00,000) will be used by Precision for remedial compliance measures.
Violations:
Precision disclosed the following violations to the Department:
Unauthorized Exports of Technical Data to Foreign-Person Employees
On October 17, 2019, Precision submitted a full voluntary disclosure describing unauthorized exports of technical data to certain foreign person employees at Precision’s wholly owned subsidiary, Mold Masters, identified as USML Category XIX(g), pertaining to tools (specifically, wax pattern and core dies) and wax patterns consumed in the subsequent production of casting blades used in gas turbine engines of 5th generation fighter aircraft to 46 FPEs, lawfully permitted to work in the United States, from Mexico, El Salvador, Honduras, Bhutan, Peru, and Burundi. Precision’s subsequent review has confirmed that eight (8) of the wax patterns relate to the hot section components for the 5th generation fighter aircraft.
Precision disclosed that, although these employees had lawful U.S. employment authorization, the prior ownership of Mold Masters’ did not validate their U.S.-person status when hiring employees for roles requiring authorization for the export of technical data or secure ITAR employee licenses. Violations persisted when FPEs present at the time of Precision’s acquisition of Mold Masters in 2018 continued to work under the same conditions through 2019. Mold Masters’ prior record keeping procedures failed to capture information such as specific dates, work assignments, or information on specific technical data.
Remedial Measures:
Precision is required to ensure that adequate resources are dedicated to ITAR compliance throughout its ITAR-regulated operating divisions, subsidiaries, and business units. Precision must establish policies and procedures for all of Precision’s employees with responsibility for AECA and ITAR compliance to address lines of authority, staffing levels, performance evaluations, and career paths.
Precision, in coordination with the Designated Official (as defined below), shall conduct an internal review of AECA and ITAR compliance resources and establish the necessary actions to ensure that sufficient resources are dedicated to AECA and IT AR compliance.
Precision shall appoint, in accordance with the provisions of the Consent Agreement and in consultation with and the approval of the Director, Defense Trade Controls Compliance – DTCC, a qualified individual to serve as a Designated Official for the entire term that the Consent Agreement is in force. The term “Designated Official” in this Consent Agreement refers to a Special Compliance Officer (SCO) 1 or Internal Special Compliance Officer (ISCO)2 during the term of their appointment.
Precision shall strengthen corporate compliance procedures focused principally on Precision’s business operations such that: (a) all Precision employees engaged in AECA and ITAR-regulated activities are
familiar with the AECA and the ITAR, and their own and Precision’s responsibilities thereunder; (b) all persons responsible for supervising those employees, including senior managers of those units, are knowledgeable about the underlying policies and principles of the AECA and the ITAR; and (c) there are records indicating the names of employees, trainers, and level and area of training received.
Precision shall enhance its AECA and ITAR compliance program with specific attention to the areas described in paragraphs 9(k)(I)(i) through 9(k)(1)(vii) of the agreement. Precision shall provide to DTCC written confirmation that the company has completed this action.
Precision agreed to implement a comprehensive, automated export compliance system throughout its operating divisions, subsidiaries, and business units engaged in AECA and ITAR-regulated activities to strengthen its internal controls for ensuring compliance with the AECA and the ITAR. This system shall track the decision process from the initiation to conclusion of a request for export, reexport, or retransfer
authorization. The automated export compliance system shall improve Precision’s ability to oversee and monitor export, reexport, and retransfer activity. This system shall also cover the initial identification of all technical data and technical assistance in any form proposed to be disclosed to any foreign persons. Precision shall ensure the use of a means of alerting users to the AECA and ITAR requirements on electronic transmissions of ITAR-controlled technical data. In order to prevent unintentional or accidental transmissions to unauthorized recipients, Precision shall also provide training lo all employees to ensure that any type of electronic transmissions of ITAR-controlled technical data are sent in accordance with Precision’s export compliance policies and procedures.
Classification Review:
Precision shall, under the supervision of the Designated Official, review, verify, and complete the export control jurisdiction of all hardware and/or software that Precision’s AECA and ITAR-regulated operating divisions, subsidiaries and business units, and any defense services or technical data, directly related to such hardware and not related to any hardware.
Also, separately, prior to export, re-export and/or retransfer, Precision shall review, verify, and complete the export control jurisdiction of each hardware item (and any defense services or technical data, including software, directly related to such hardware item and not related to any hardware) and items procured from
suppliers for which such jurisdiction was not previously and accurately determined and/or verified in accordance with this paragraph.
Audits:
One audit shall be performed during the Consent Agreement. Precision shall have the audit conducted by an outside consultant with expertise in AECA and ITAR matters, approved by the Director, DTCC. The audit shall be conducted under the supervision of the Designated Official. The audit shall provide a thorough assessment of the effectiveness of Precision’s implementation of all measures set forth in this Consent Agreement with focus on those actions undertaken to address the compliance issues identified in the Proposed Charging Letter, the policies, procedures, and training established by Precision. The Designated Official or the Director, DTCC, may identify other areas (e.g., transactional review of agreements, Precision’s information technology systems) for the audit.
Debarment:
Precision has cooperated with the Department’s review, has expressed regret for these activities, and has taken steps to improve its compliance programs. It has also undertaken to pay a cash penalty and agrees to implement the significant additional remedial compliance actions specified in the Consent Agreement. For these reasons, the Department has determined not to impose an administrative debarment of Precision.
Onsite Reviews by the Department:
For the purpose of assessing compliance with the provisions of the AECA, the ITAR and future authorizations, Precision agreed to arrange and facilitate, with minimum advance notice, onsite reviews by the Department while this Consent Agreement remains in effect.
Copies of the Charging Letter, Agreement and Order can be found at the following links:
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=52a07c224701d21827972464336d4375 and
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=a5a07c224701d21827972464336d436e and
https://www.pmddtc.state.gov/sys_attachment.do?sys_id=4aa07c224701d21827972464336d4372
Editor’s note: The compliance measures described here are representative of the direction the Department of State is taking with larger companies and their compliance programs. However small companies should review to align their programs to focus on the same compliance points noted.
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October 9, 2024: Zhanna Soldatenkova and Ruslan Almetov, both Russian nationals, were indicted along with Arthur Petrov, a dual Russian and German national, for export control violations, smuggling, wire fraud, and money laundering in connection with their alleged participation in a scheme to procure U.S.-sourced microelectronics subject to U.S. export controls on behalf of a Russia-based supplier of critical electronics components for manufacturers supplying weaponry and other equipment to the Russian military.
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October 17, 2024: Lin Chen pleaded guilty in federal court to illegally exporting U.S. technology to a prohibited end user in China, in violation of the International Emergency Economic Powers Act (IEEPA) and the Export Administration Regulations (EAR). The plea was accepted by the Hon. William Alsup, Senior U.S. District Judge.
In pleading guilty, Chen, 65, a citizen of the People’s Republic of China (PRC), admitted to acting on behalf of Jiangsu Hantang International Trade Group Corp., Ltd. (JHI), a company headquartered in Nanjing, PRC, to procure a wafer cutting machine on behalf of Chengdu GaStone Technology Co., Ltd. (GaStone), an entity located in Chengdu, PRC. Chen admitted to knowing that GaStone was designated on the U.S. Department of Commerce’s Entity List on Aug. 1, 2014. Federal regulations restrict the export of certain items to companies, research institutions, and other entities identified on the Department of Commerce’s Entity List. Under applicable Department of Commerce regulations, wafer cutting machines, which are used to cut thin semiconductors used in electronics (also known as silicon wafers), require a license for export to end-users such as GaStone.
Chen’s sentencing hearing is scheduled for January 28, 2025, before the Judge Alsup. The maximum statutory penalty for an IEEPA violation is up to 20 years in prison and a $1 million fine. However, any sentence will be imposed by the court only after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition of a sentence.
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October 17, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced an $860,000 settlement with Vietnam Beverage Company Limited (VBCL). VBCL, a Vietnam-based alcoholic beverage company, has agreed to settle its subsidiaries’ potential civil liability for 43 apparent violations of the North Korea Sanctions Regulations. Between April 2016 and October 2018, VBCL’s subsidiaries caused U.S. financial institutions to process approximately $1,141,547 in payments for the sale of alcoholic beverages to North Korea. This settlement amount reflects OFAC’s determination that conduct at issue was not voluntarily disclosed and constituted a non-egregious case.
https://ofac.treasury.gov/recent-actions/20241017_33 and
https://ofac.treasury.gov/media/933501/download?inline
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October 25, 2024: Yuksel Senbol, 36, of Orlando, Florida, was sentenced to 15 months in prison for conspiracy to defraud the United States, conspiracy to commit wire fraud, wire fraud, conspiracy to commit money laundering, money laundering, conspiracy to violate the Export Control Reform Act, violating the Export Control Reform Act, and violating the Arms Export Control Act. As part of her sentence, the court also entered an order of forfeiture in the amount of $275,430.90, the proceeds of Senbol’s fraud and money laundering scheme. Senbol pleaded guilty on May 7.
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October 25, 2024: A federal jury convicted Brian Assi, also known as Brahim Assi, of conspiring to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), attempted unlawful export of goods from the United States to Iran without a license, attempted smuggling goods from the United States, submitting false or misleading export information, and conspiracy to commit money laundering. Sentencing Brian Assi is scheduled for Jan. 7, 2025.
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October 28, 2024: The Ninth U.S. Circuit Court of Appeals affirmed the 7-year prison sentence of a former UCLA electrical engineering adjunct professor relating to his exporting of military-grade semiconductor chips without a license to China in collaboration with a Chinese enterprise that develops weapons.
Federal regulations found in the International Emergency Economic Powers Act (“IEEPA”) require that a license be obtained for the export of certain items, which are assigned an Export Control Classification Number (“ECCN”). The list of ECCNs provides the “reasons for control” associated with each number.
In July 2019, a jury found Shih guilty of 18 counts of violating various offenses arising out of the export of the MMICs, including a violation of the IEEPA based on the fact that the semiconductor chips were assigned ECCNs that listed national security as a reason for control.
Senior District Court Judge John A. Kronstadt of the Central District of California ordered entry of a judgment of acquittal on the violation of the IEEPA violation, finding that the government had not proven that a license was required to export the MMICs, and declined to apply a sentencing enhancement providing for a higher base level if national security controls were evaded.
The Ninth Circuit reversed and reinstated the conviction on the overturned count. Kronstadt, on remand, applied the enhancement and sentenced Shih to two 7-year terms of imprisonment, to be run concurrently.
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October 30, 2024: The Commerce Department’s Bureau of Industry and Security (BIS) is adding 40 foreign entities, as well as 4 addresses, to the Entity List in connection with their support for the Kremlin’s illegal war in Ukraine and tightening restrictions on 49 foreign entities that were already on the Entity List to address their procurement of high-priority U.S.-branded microelectronics and other items on behalf of Russia. These entities are located in the People’s Republic of China (PRC), as well as India, Malaysia, Russia, Singapore, Türkiye, Estonia, Finland, the United Arab Emirates (UAE), and the United Kingdom (UK). BIS is also imposing additional restrictions on the export of 9 chemical precursors used to produce riot control agents (RCAs) and chemical weapons used on the battlefield against Ukraine in violation of treaty commitments. These actions underscore the extensive controls the United States has placed on entities enabling Russian aggression against Ukraine since the further invasion in February 2022.
Sanctions
Department of Commerce, Bureau of Industry and Security (BIS)
October 16, 2024: 89 Fed. Reg. 834428: The Bureau of Industry and Security (BIS) amended the Export Administration Regulations (EAR) by adding eight persons to the Unverified List (UVL). Of the eight persons being added, three are under the destination of China, People’s Republic of (China); two are under the destination of Germany; one is under the destination of Pakistan; and two are under the destination of Türkiye. BIS is also amending the EAR by removing two persons from the UVL. Of the two persons being removed, one is under the destination of Saudi Arabia, and the other is under the destination of China.
Additions to the UVL:
- Hengye Technology Co., Ltd of China;
- Skytop Electronics Ltd. of China;
- YXS Technology Co., Ltd. of China;
- Arabian Aviation Trade Group of Germany;
- Tiptrans Limited of Germany;
- Marshal Traders of Pakistan;
- Pegasus Technic Services of Turkey;
- Vast Polymers of Turkey; and
- Ambalaj Sanayi Ve Ticaret Limited Sirketi of Turkey.
https://www.federalregister.gov/documents/2024/10/16/2024-23638/revisions-to-the-unverified-list
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October 21, 2024: the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 26 entities to the Entity List for activities contrary to U.S. national security and foreign policy under the destinations of the People’s Republic of China (PRC) (6), Egypt (1), Pakistan (16), and the United Arab Emirates (UAE) (3). These additions are related to alleged violations of export controls, involvement in weapons programs of concern, and evasion of U.S. sanctions and export controls on Russia and Iran.
Nine of the entities under the destination of Pakistan were added for acting as front companies and procurement agents for the Advanced Engineering Research Organization, a Pakistan-based company added to the Entity List in 2014. The remaining 7 Pakistani entities were added for contributions to Pakistan’s ballistic missile program.
Three entities under the destination of the UAE and one under the destination of Egypt were added for acquiring and attempting to acquire U.S.-origin parts to evade U.S. sanctions and export controls imposed following Russia’s full-scale invasion of Ukraine in February 2022.
Six entities under the destination of the PRC were added for acquiring U.S.-origin items in support of the PRC’s military modernization, dilatory and evasive conduct during end-use checks, and procurement of U.S.-origin items for Iran’s weapons of mass destruction and unmanned aerial vehicle (UAV) programs.
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October 30, 2024: The Commerce Department’s Bureau of Industry and Security (BIS) is adding 40 foreign entities, as well as 4 addresses, to the Entity List in connection with their support for the Kremlin’s illegal war in Ukraine and tightening restrictions on 49 foreign entities that were already on the Entity List to address their procurement of high-priority U.S.-branded microelectronics and other items on behalf of Russia. These entities are located in the People’s Republic of China (PRC), as well as India, Malaysia, Russia, Singapore, Türkiye, Estonia, Finland, the United Arab Emirates (UAE), and the United Kingdom (UK). BIS is also imposing additional restrictions on the export of 9 chemical precursors used to produce riot control agents (RCAs) and chemical weapons used on the battlefield against Ukraine in violation of treaty commitments. These actions underscore the extensive controls the United States has placed on entities enabling Russian aggression against Ukraine since the further invasion in February 2022.
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Department of the Treasury, Office of Foreign Assets Control (OFAC)
October 1, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated seven individuals, and two entities associated with the Russia-based cybercriminal group Evil Corp, in a tri-lateral action with the United Kingdom’s Foreign, Commonwealth & Development Office (FCDO) and Australia’s Department of Foreign Affairs and Trade (DFAT). On December 5, 2019, OFAC designated Evil Corp, its leader and founder Maksim Viktorovich Yakubets and over a dozen Evil Corp members, facilitators, and affiliated companies pursuant to Executive Order (E.O.) 13694, as amended by E.O. 13757 (“E.O. 13694, as amended”). The United Kingdom and Australia concurrently designated select Evil Corp-affiliated individuals designated by OFAC. Additionally, the U.S. Department of Justice has unsealed an indictment charging one Evil Corp member in connection with his use of BitPaymer ransomware targeting victims in the United States. This designation also coincides with the second day of the U.S.-hosted Counter Ransomware Initiative summit which involves over 50 countries working together to counter the threat of ransomware.
The following individuals have been added to OFAC’s SDN List:
- Benderskit, Eduard Vitalyevich of Russia;
- Pogodin, Vadim Gennadievich of Russia;
- Ramazanov, Beyat Enverovich of Russia;
- Ryzhenkov, Aleksandr Viktorovich of Russia;
- Ryzehenkov, Sergey Viktorovich of Russia;
- Shchetinin, Aleksey, Yevgenevich of Russia; and
- Yakubets, Viktor Grigoryevich of Russia.
The following individuals have been added to OFAC’s SDN List:
- Solar-Invest LLC of Russia; and
- Vympel-Assistance LLC of Russia.
https://ofac.treasury.gov/recent-actions/20241001 and
https://home.treasury.gov/news/press-releases/jy2623
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October 1, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Hilltop Youth, a violent extremist group that has repeatedly attacked Palestinians and destroyed Palestinian homes and property in the West Bank, pursuant to Executive Order (E.O.) 14115. Through these violent activities, Hilltop Youth is actively destabilizing the West Bank and harming the peace and security of Palestinians and Israelis alike. Hilltop Youth has devastated Palestinian communities and carried out killings, mass arson, and other so-called “price tag” attacks to exact revenge and intimidate Palestinian civilians, and has repeatedly clashed with the Israeli military as it counters their activities.
The following individuals have been added to OFAC’s SDN List:
- Suissa, Avichai of Israel; and
- Yardeni, Eitan of Russia.
The following entities have been added to OFAC’s SDN List:
- Hilltop Youth.
https://ofac.treasury.gov/recent-actions/20241001 and
https://home.treasury.gov/news/press-releases/jy2622
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October 2, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated one individual and three companies that have facilitated weapons procurement and smuggling operations for Ansarallah, commonly known as the Houthis. This action targets key procurement operatives and suppliers located in Iran and the People’s Republic of China (PRC) that have enabled the Houthis to acquire dual-use materials and components needed to manufacture, maintain, and deploy an arsenal of advanced missiles and unmanned aerial vehicles (UAVs) against U.S. and allied interests.
The following individual has been added to OFAC’s SDN List:
- Al-kulani, Hasan Ahmad Hasan Muhammad of Iran.
The following entities have been added to OFAC’s SDN List:
- Gemini Marine Limited of the Marshall Islands;
- Shenzhen Boyu Imports and Exports Co. of China; and
- Shenzhen Jinghon Electronics Limited of China.
The following vessels have been added to OFAC’s SDN List:
- Frunze (E5U4323) Crude Oil Tanker Cook Islands flag; Registration Identification IMO 9263643; MMSI 518998343 (vessel); and
- Izumo (TRBQ9) Crude Oil Tanker Gabon flag; Vessel Registration Identification IMO 9249324; MMSI 626466000 (vessel).
https://home.treasury.gov/news/press-releases/jy2627 and
https://ofac.treasury.gov/recent-actions/20241002
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October 7, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and one sham charity that are prominent international financial supporters of Hamas, as well as one Hamas-controlled financial institution in Gaza. OFAC also designated a longstanding Hamas supporter and nine of his businesses. These actors play critical roles in external fundraising for Hamas, often under the guise of charitable work, that finance the group’s terrorist activities. This action, which is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, highlights the abuse of the non-profit organization (NPO) sector by terrorist financiers through the use of sham charities to generate revenue.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) also issued Counter Terrorism General License 30, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 7, 2024,” and Counter Terrorism General License 31, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on October 7, 2024.”
General License 30: Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 7, 2024
All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked persons are authorized through 12:01 a.m. eastern standard time, November 21, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with the GTSR:
(1) Al Ahmar Trading Group;
(2) Al Salam Trading and Agencies General Establishment;
(3) Sabaturk Dis Ticaret Anomin Sirketi;
(4) Vivid Enerji Yatirimlari Anonim Sirketi;
(5) Investrade Portfoy Yonetimi Anomim Sirketi; or
(6) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.
General License 31: Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on October 7, 2024
(a) All transactions prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity of Investrade Portfoy Yonetimi Anomim Sirketi (Investrade Portfoy), and any entity in which Investrade Portfoy owns, directly or indirectly, a 50 percent or greater interest ( “Covered Debt or Equity”), to a non-U.S. person are authorized through 12:01 am eastern standard time November 21, 2024:
(b) All transactions prohibited by the GTSR that are ordinarily incident and necessary to facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. eastern daylight time, October 7, 2024, are authorized through 12:01 a.m. eastern standard time November 21, 2024.
(c) All transactions prohibited by the GTSR that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern daylight time, October 7, 2024, that (i) include a blocked person described in paragraph (a) of this general license as a counterparty or (ii) are linked to Covered Debt or Equity are authorized through 12:01 a.m. eastern standard time, November 21, 2024, provided that any payments to a blocked person are made into a blocked account in accordance with the GTSR.
The following individuals have been added to OFAC’s SDN List:
- Al Ahmar, Hamid Abdullah Hussein of Yemen;
- Al-zeer, Majed of Jordan;
- Doughman, Abel Saad al-Din Hassan of Austria; and
- Hanoun, Muhammad Mahoud Ahmad Awad of Jordan.
The following entities have been added to OFAC’s SDN List:
- Al Ahmar Oils and Supply Distribution of Yemen;
- Al Ahmar Trading Group of Yemen;
- Al Salam Trading and Agencies General Establishment of Yemen;
- Al-Intaj Bank of Gaza;
- Associazione Benefica Di Soldarieta of Italy;
- Investrade Portfoy Yonetimi Anonim Sirketi of Turkey;
- Saba , Trade & Investment S.R.O of Czech Republic;
- Sabafon International Sal Offshore of Lebanon;
- Sabaturk Dis Ticaret Anonim Sirketi of Turkey;
- Sama International Media of Yemen; and
- Vivid Enerji Yatirimlari Anonim Sirketi of Turkey.
https://ofac.treasury.gov/recent-actions/20241007 and
https://home.treasury.gov/news/press-releases/jy2632 and
https://ofac.treasury.gov/media/933471/download?inline and
https://ofac.treasury.gov/media/933476/download?inline and
https://ofac.treasury.gov/media/933481/download?inline
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October 8, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Algoney Hamdan Daglo Musa (Algoney), pursuant to Executive Order (E.O.) 14098, for leading efforts to supply weapons to continue the war in Sudan. The war between the Sudanese Armed Forces (SAF) and the Rapid Support Forces (RSF) has caused immense devastation, leaving tens of thousands dead, more than 11 million displaced, and millions facing emergency levels of hunger. Algoney is the procurement director of the RSF and a brother of Mohammed Hamdan Daglo (Hemedti), the leader of the RSF. Algoney has extended this war by leading RSF efforts to procure weapons and military materiel. By arming the RSF, his actions have directly contributed to the RSF’s ongoing siege of El Fasher in North Darfur, a city of nearly two million vulnerable civilians, and the RSF’s operations elsewhere in Sudan.
The following individual has been added to OFAC’s SDN List:
- Musa, Algoney Hamdan Daglo of Sudan.
https://home.treasury.gov/news/press-releases/jy2635 and
https://ofac.treasury.gov/recent-actions/20241008
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October 10, 2024: OFAC issued a new Russia-related Frequently Asked Question (FAQ): 1197.
FAQ 1197:
Q: I’m a U.S. person with securities held at the National Settlement Depository (NSD), which were transferred pursuant to Russian Decree 840 to another Russian registrar. Am I required to block these securities?
A: Yes. On June 12, 2024, OFAC designated the National Settlement Depository (NSD), along with the Moscow Exchange (MOEX) and the National Clearing Center (NCC) pursuant to E.O. 14024 for operating or having operated in the financial services sector of the Russian Federation economy. As noted in the accompanying press release, Russia has reoriented the architecture of its financial system to facilitate investment into its defense industry and acquisition of goods needed to further its aggression against Ukraine.
Alongside this designation, OFAC issued, and subsequently extended, two general licenses to allow for wind-down of certain transactions involving NSD, MOEX, and NCC, and the divestment of securities held at NSD, among other authorized activities. These general licenses (General License 99A and General License 100A) are in place through 12:01 a.m. eastern daylight time, October 12, 2024. Following the expiration of GLs 99A and 100A, any securities in the possession or control of U.S. persons that are held at NSD should be treated as blocked, and dividends or other income received via NSD should be treated as blocked.
OFAC is aware that the Russian Federation has attempted to take action to evade or avoid OFAC sanctions on NSD via Presidential Decree 840 by requiring the transfer of certain securities to local Russian registrars. OFAC cautions that such transfers may not be authorized under the general licenses and may be considered null and void pursuant to OFAC’s regulations (see 31 CFR § 587.202). OFAC understands that these transactions may involve other blocked persons, including certain local Russian registrars. OFAC is also investigating the remaining non-blocked local Russian registrars for future designation under E.O. 14024. The general licenses do not authorize transactions involving any blocked person other than those identified in the authorizations, and any transfer made in violation of OFAC sanctions is null and void. As such, U.S. persons should continue to treat these securities as blocked.
https://ofac.treasury.gov/faqs/1197 and
https://ofac.treasury.gov/recent-actions/20241010
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October 11, 2024: The United States expanded sanctions on Iran’s petroleum and petrochemical sectors in response to Iran’s October 1 attack on Israel, its second direct attack on Israel this year. This action intensifies financial pressure on Iran, limiting the regime’s ability to earn critical energy revenues to undermine stability in the region and attack U.S. partners and allies. The Secretary of the Treasury, in consultation with the Secretary of State, is identifying the petroleum and petrochemical sectors of the Iranian economy pursuant to section 1(a)(i) of Executive Order (E.O.) 13902, which allows Treasury to target a broader range of activities relating to Iran’s trade in petroleum and petrochemical products. E.O. 13902 provides authority to identify and impose sanctions on key sectors of Iran’s economy to deny the Iranian government financial resources that may be used to fund and support its nuclear program, missile development, terrorism and terrorist proxy networks, and malign regional influence. Pursuant to this determination, the Treasury may impose sanctions on any person determined to operate in the petroleum and petrochemical sectors of the Iranian economy.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a Determination pursuant to Section 1(a)(i) of Executive Order 13902, “Petroleum and Petrochemical Sectors of the Iranian Economy”.
The following entities have been added to OFAC’s SDN List:
- Alya Marine Sendirian Berhad of Malaysia;
- Cathay Harvest Marine Ltd of China;
- Celia Armas Ltd of China;
- Davina Shipping Inc of the Marshall Islands;
- Delnaz Ship Management SDN BHD of Malaysia;
- Derecttor Company Limited of China;
- Diamante Tankers Incorporated of Panama;
- Elza Shipping SA of Liberia;
- Engen Management NV of Suriname;
- Gabbaro Ship Services Pvt Ltd of Mumbai;
- Glazing Future Management NV of Suriname;
- Harry Victor Ship Management and Operation L.L.C. of the United Arab Emirates;
- Jazira Das International Refinded Oil Products Trading L.L.C. of the United Arab Emirates;
- Max Maritime Solutions FZE of the United Arab Emirates;
- Rita Shipping Inc of the Marshall Islands; and
- Strong Roots Provider NV of Suriname.
The following vessels have been added to OFAC’s SDN List:
- Anhona (V3GK3) Oil Products Tanker Belize flag; MMSI 312171000 (vessel);
- Aventus I (3E2078) Crude Oil Tanker Panama flag; MMSI 352898820 (vessel);
- Bendingo (8P2397) Crude Oil Tanker Barbados flag; MMSI 314925000 (vessel);
- Berg 1 (3DCZ1) Crude Oil Tanker Panama flag; (vessel);
- Carina (8P2232) Crude Oil Tanker Barbados flag; MMSI 314872000 (vessel);
- Carnatic (8P2398) Crude Oil Tanker Barbados flag; MMSI 314926000 (vessel);
- Carol (V4BC4) LPG Tanker St. Kitts and Nevis flag; MMSI 341575000 (vessel);
- Cross Ocean (3E4640) Crude Oil Tanker Panama flag; MMSI 352002860 (vessel);
- Crystal Rose (3E4037) Crude Oil Tanker Panama flag; MMSI 352001298 (vessel);
- Davina T8A4843) Crude Oil Tanker Palau flag; MMSI 511101471 (vessel);
- Dimitra II (T7BI5) Crude Oil Tanker San Marino flag; MMSI 268249801 (vessel);
- Elza (D5SE4) Crude Oil Tanker Liberia flag; MMSI 636018950 (vessel);
- Goodwin (E5U5022) Crude Oil Tanker Cook Islands flag; MMSI 518999041 (vessel);
- Hornet, Crude Oil Tanker Eswatini flag; MMSI 6987100 (vessel);
- Luna Prime (3E2167) Crude Oil Tanker Panama flag; MMSI 352001994 (vessel);
- Octans (S9A15) Crude Oil Tanker Sao Tome and Principe flag; (vessel);
- Salvia (T7BJ6) Crude Oil Tanker San Marino flag; MMSI 268240702 (vessel);
- Satina (3E2250) Products Tanker Panama flag; MMSI 352002316 (vessel);
- Shanaye Queen (9WNN6) Crude Oil Tanker Malaysia flag; MMSI 533132105 (vessel);
- Spirit of Casper (3E6116) Crude Oil Tanker Panama flag; MMSI 352003872 (vessel);
- Tyche I (3E5017) Crude Oil Tanker Panama flag; MMSI 352002704 (vessel);
- Voras (TJM8VO) Crude Oil Tanker Cameroon flag; MMSI 613916701 (vessel); and
- Wen Yao (E5U5189) Crude Oil Tanker Cook Islands flag; MMSI 518999208 (vessel).
https://home.treasury.gov/news/press-releases/jy2644 and
https://ofac.treasury.gov/media/933491/download?inline and
https://ofac.treasury.gov/recent-actions/20241011
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October 15, 2024: In a joint action with Canada, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Samidoun Palestinian Prisoner Solidarity Network, or “Samidoun,” a sham charity that serves as an international fundraiser for the Popular Front for the Liberation of Palestine (PFLP) terrorist organization. The PFLP, which was designated as a Foreign Terrorist Organization and a Specially Designated Global Terrorist by the U.S. Department of State in October 1997 and October 2001, respectively, uses Samidoun to maintain fundraising operations in both Europe and North America. Also designated is Khaled Barakat, a member of the PFLP’s leadership. Together, Samidoun and Barakat play critical roles in external fundraising for the PFLP. This action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended.
The following individual has been added to OFAC’s SDN List:
- Barakat, Khaled of Canada.
The following entity has been added to OFAC’s SDN List:
- Samidoun Palestinian Prisoner Solidarity Network of Canada.
https://home.treasury.gov/news/press-releases/jy2646 and
https://ofac.treasury.gov/recent-actions/20241015
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October 16, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals, and four associated companies involved in a Lebanon-based sanctions evasion network that generates millions of dollars in revenue for Hizballah. Hizballah’s finance team is responsible for the establishment and operation of Hizballah commercial projects throughout Lebanon, some of which are financed and facilitated by Iran. OFAC also designated three individuals involved in the illegal production and trafficking of Captagon that has benefitted Bashar al-Assad’s regime and its allies, including Hizballah. The illegal trade in Captagon, a dangerous, highly addictive amphetamine, has become a billion-dollar illicit enterprise operated by senior members of the Syrian regime.
The following individuals have been added to OFAC’s SDN List:
- Atwi, Silvana of Lebanon;
- Falhout, Raji of Syria;
- Ghaffar, Haidar Houssam Al Din Abdul of Lebanon;
- Hamadi, Houssam Hasan of Lebanon;
- Hamideh, Abdellatif of Syria; and
- Hamieh, Khaldoun of Syria.
The following entities have been added to OFAC’s SDN List:
- Global Tradeline Sarl of Lebanon;
- GM Farm of Lebanon;
- Liban Oui Sarl of Lebanon; and
- United Sons of Lebanon.
https://ofac.treasury.gov/recent-actions/20241016 and
https://home.treasury.gov/news/press-releases/jy2648
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October 17, 2024: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) targeted three entities and one individual for their involvement in the development and production of Russia’s Garpiya series long-range attack unmanned aerial vehicle (UAV). The Garpiya has been deployed by Russia in its brutal war against Ukraine, destroying critical infrastructure and causing mass casualties. Designed and developed by People’s Republic of China (PRC)-based experts, the Garpiya is produced at PRC-based factories in collaboration with Russian defense firms before transferring the drones to Russia for use against Ukraine.
These private companies and individuals were involved in the development and production of military equipment for a U.S.-sanctioned Russian defense firm for use by the Russian military in Ukraine. While the United States previously imposed sanctions on PRC entities providing critical inputs to Russia’s military-industrial base, these are the first U.S. sanctions imposed on PRC entities directly developing and producing complete weapons systems in partnership with Russian firms.
The following individual have been added to OFAC’s SDN List:
- Yamshchikov, Artem Mikhailovich of Russia.
The following entites have been added to OFAC’s SDN List:
- Limited Liability Company Trading House Vector of Russia;
- Redlepus Vector Industry Shenzhen Co Ltd of China; and
- Xiamen Limbach Aircraft Engine Co., Ltd. of China.
https://home.treasury.gov/news/press-releases/jy2651 and
https://ofac.treasury.gov/recent-actions/20241017
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October 17, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eighteen companies, individuals, and vessels for their ties to Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial official Sa’id al-Jamal (al-Jamal) and his network. Included in this action are the captains of vessels transporting illicit oil as well as the companies that managed and operated these ships. The revenue from al-Jamal’s network continues to enable Houthi attacks in the region, including missile and unmanned aerial vehicle attacks on Israel and commercial vessels transiting the Red Sea.
The following individuals have been added to OFAC’s SDN List:
- Barkhordar, Ali of Iran;
- Durrani, Whaid Ullah of Pakistan;
- Keot, Dipankar Mohan of India;
- Skiriban, Yevhen of Ukraine; and
- Warikoo Rattanlal, Rahul Rattanlal of India.
The following entities have been added to OFAC’s SDN List:
- Changtai Shipping Limited of the Marshall Islands;
- Eco Max Fze of the United Arab Emirates;
- Eco Max Trading Fze of the United Arab Emirates;
- Indo Gukf Ship Management LLC of the United Arab Emirates;
- Motionavigations Limited of the Marshall Islands.
The following vessels have been added to OFAC’s SDN List:
- Gratia (T8A4616) Chemical/Oil Tanker Palau flag; MMSI 511101304 (vessel);
- Juvenis (T8A4619) Chemical/Oil Tanker Palau flag; MMSI 511101307 (vessel);
- Kapok (3E6616) Crude Oil Tanker Panama flag; MMSI 352003068 (vessel);
- Kukki (8PVO7) Chemical/Oil Tanker Barbados flag; MMSI 314823000 (vessel);
- Liana (T8A3765) Oil Products Tanker Palau flag; MMSI 511100596 (vessel);
- Marbel (E5U4474) Chemical/Oil Tanker Cook Islands flag; MMSI 518998494 (vessel);
- Onyx (E5U4643) Products Tanker Cook Islands flag; MMSI 518998663 (vessel); and
- Trophy (E5U4515) Chemical/Oil Tanker Cook Islands flag; MMSI 518998535 (vessel).
https://home.treasury.gov/news/press-releases/jy2652 and
https://ofac.treasury.gov/recent-actions/20241017
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October 21, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued an updated Maritime Oil Industry Advisory for both government and private sector actors involved in the global maritime industry. Updates to the advisory include recommendations concerning specific best practices and reflects the Price Cap Coalition’s ongoing commitment to promote responsible practices in the industry, disrupt sanctioned trade, and enhance compliance with the price cap.
The Price Cap Coalition, which includes G7 countries as well as the European Union, Australia, and New Zealand, is updating its advisory for both government and private sector actors involved in the global maritime industry. The advisory provides recommendations concerning specific best practices and reflects the Coalition’s ongoing commitment to promoting responsible practices in the industry, disrupting sanctioned trade, and enhancing compliance with the price cap.
The Coalition originally published its advisory on October 12, 2023. This update provides stakeholders with new recommendations on meeting international obligations, enhancing due diligence around tanker sales, avoiding interactions with sanctioned counterparties, and raising internal awareness.
The Coalition remains focused on reducing the revenues Russia uses to fuel its brutal war against Ukraine while maintaining energy market stability.
https://home.treasury.gov/news/press-releases/jy2659 and
https://ofac.treasury.gov/recent-actions/20241021
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October 24, 2024: the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Mirghani Idris Suleiman (Idris) pursuant to Executive Order (E.O.) 14098, for leading the Sudanese Armed Forces’ (SAF) efforts to acquire weapons for use in its ongoing war with the Rapid Support Forces (RSF). Idris has been at the center of weapons deals that have fueled the brutality and scale of the war, serving as Director General of Defense Industries System (DIS), the SAF’s primary weapons production and procurement arm. OFAC designated DIS on June 1, 2023, for being responsible for, or complicit in, or having directly or indirectly engaged or attempted to engage in actions or policies that threaten the peace, security, or stability of Sudan,
The following individual have been added to OFAC’s SDN List:
Suleiman, Mirghani Idris of Sudan.
https://ofac.treasury.gov/recent-actions/20241024 and
https://home.treasury.gov/news/press-releases/jy2672
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October 30, 2024: The U.S. Department of the Treasury sanctioned 275 individuals and entities involved in supplying Russia with advanced technology and equipment that it desperately needs to support its war machine. This action targets both individual actors and sprawling sanctions evasion networks across 17 jurisdictions, including India, the People’s Republic of China (PRC), Switzerland, Thailand, and Türkiye. In addition to disrupting global evasion networks, this action also targets domestic Russian importers and producers of key inputs and other materiel for Russia’s military-industrial base.
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Russia-related General License 8K, “Authorizing Transactions Related to Energy,” Russia-related General License 25G, “Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications,” Russia-related General License 110, “Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 30, 2024,” Russia-related General License 111, “Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on October 30, 2024,” and Russia-related General License 112, “Authorizing Civil Aviation Safety and Wind Down Transactions Involving Shaurya Aeronautics Private Limited.”
Additionally, OFAC has issued one new Russia-related Frequently Asked Question (FAQ 1198).
GENERAL LICENSE NO. 8K: Authorizing Transactions Related to Energy
(a) All transactions prohibited by Executive Order (E.O.) 14024 involving one or more of the following entities that are related to energy are authorized, through 12:01 a.m. eastern daylight time, April 30, 2025:
(1) State Corporation Bank for Development and Foreign Economic Affairs Vnesheconombank;
(2) Public Joint Stock Company Bank Financial Corporation Otkritie;
(3) Sovcombank Open Joint Stock Company;
(4) Public Joint Stock Company Sberbank of Russia;
(5) VTB Bank Public Joint Stock Company;
(6) Joint Stock Company Alfa-Bank;
(7) Public Joint Stock Company Rosbank;
(8) Bank Zenit Public Joint Stock Company;
(9) Bank Saint-Petersburg Public Joint Stock Company;
(10) National Clearing Center (NCC);
(11) Any entity in which one or more of the above persons own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest; or
(12) the Central Bank of the Russian Federation.
(b) For the purposes of this general license, the term “related to energy” means the extraction, production, refinement, liquefaction, gasification, regasification, conversion, enrichment, fabrication, transport, or purchase of petroleum, including crude oil, lease condensates, unfinished oils, natural gas liquids, petroleum products, natural gas, or other products capable of producing energy, such as coal, wood, or agricultural products used to manufacture biofuels, or uranium in any form, as well as the development, production, generation, transmission, or exchange of power, through any means, including nuclear, thermal, and renewable energy sources.
GENERAL LICENSE NO. 25G: Authorizing Transactions Related to Telecommunications and Certain Internet-Based Communications
(a) All transactions ordinarily incident and necessary to the receipt or transmission of telecommunications involving the Russian Federation that are prohibited by the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR), are authorized.
(b) The exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, wherever located, to the Russian Federation of services incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, user authentication services, web hosting, and domain name registration services, that is prohibited by the RuHSR, is authorized.
(c) The exportation or reexportation, sale, or supply, directly or indirectly, from the United States or by U.S. persons, to the Russian Federation of software, hardware, or technology incident to the exchange of communications over the internet is authorized, provided that:
(1) If the software, hardware, or technology is subject to the Export Administration Regulations, 15 CFR parts 730 through 774 (EAR), the exportation, reexportation, sale, or supply to the Russian Federation of such software, hardware, or technology is licensed or otherwise authorized by the Department of Commerce pursuant to the EAR; and
(2) If the software, hardware, or technology is not subject to the EAR, the exportation, reexportation, sale, or supply to the Russian Federation of such software, hardware, or technology would be eligible for a license exception or otherwise authorized by the Department of Commerce if it were subject to the EAR.
GENERAL LICENSE NO. 110: Authorizing the Wind Down of Transactions Involving Certain Entities Blocked on October 30, 2024
(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the wind down of any transaction involving one or more of the following blocked entities are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that any payment to a blocked person is made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR):
(1) XH Smart Tech China Co Ltd;
(2) Lokesh Machines Limited;
(3) Galaxy Bearings Ltd;
(4) Orbit Fintrade LLP;
(5) Wuhan Huazhong Numerical Control Co Ltd;
(6) Beijing Dynamic Power Co Limited;
(7) Sharpline Automation Private Limited; or
(8) Any entity in which one or more of the above persons own, directly or indirectly, individually or in aggregate, a 50 percent or greater interest.
GENERAL LICENSE NO. 111: Authorizing Certain Transactions Related to Debt or Equity of, or Derivative Contracts Involving, Certain Entities Blocked on October 30, 2024
- a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by the following blocked entities (“Covered Debt or Equity”) to a non-U.S. person are authorized through 12:01 a.m. eastern standard time, December 14, 2024:
(1) XH Smart Tech China Co Ltd;
(2) Lokesh Machines Limited;
(3) Galaxy Bearings Ltd;
(4) Beijing Dynamic Power Co Limited;
(5) Wuhan Huazhong Numerical Control Co Ltd; or
(6) Any entity in which one or more of the above persons own, directly or indirectly, individually or in aggregate, a 50 percent or greater interest.
(b) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to facilitating, clearing, and settling trades of Covered Debt or Equity that were placed prior to 4:00 p.m. eastern daylight time, October 30, 2024 are authorized through 12:01 a.m. eastern standard time, December 14, 2024.
(c) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the wind down of derivative contracts entered into prior to 4:00 p.m. eastern daylight time, October 30, 2024 that (i) include a blocked person described in paragraph (a) of this general license as a counterparty or (ii) are linked to Covered Debt or Equity are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that any payments to a blocked person are made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
GENERAL LICENSE NO. 112: Authorizing Civil Aviation Safety and Wind Down Transactions Involving Shaurya Aeronautics Private Limited
(a) All transactions prohibited by Executive Order (E.O.) 14024 that are ordinarily incident and necessary to the provision, exportation, or reexportation of goods, technology, or services to ensure the safety of civil aviation involving Shaurya Aeronautics Private Limited (Shaurya), or any entity in which Shaurya owns, directly or indirectly, a 50 percent or greater interest (collectively, the “Blocked Persons”), are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that the goods, technology, or services that are provided, exported, or reexported are for use on aircraft operated solely for civil aviation purposes.
(b) All transactions prohibited by E.O. 14024 that are ordinarily incident and necessary to the wind down of any transaction involving the Blocked Persons, are authorized through 12:01 a.m. eastern standard time, December 14, 2024, provided that any payment to the Blocked Persons must be made into a blocked account in accordance with the Russian Harmful Foreign Activities Sanctions Regulations, 31 CFR part 587 (RuHSR).
FAQ 1198:
Q: In light of the designation of Shreya Life Sciences Private Limited (Shreya), are U.S. persons authorized to engage in transactions related to pharmaceutical and other humanitarian-related goods involving Shreya and its subsidiaries?
A: Yes. As a general matter, humanitarian trade is not the target of U.S. sanctions.
OFAC has issued Russia-related General License (GL) 6D, which authorizes, among other things, certain transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. U.S. persons may continue to engage in authorized transactions involving Shreya under GL 6D. Additionally, non-U.S. persons generally would not face sanctions risk for engaging in transactions authorized for U.S. persons under general licenses issued pursuant to the Russian Harmful Foreign Activities Sanctions program. For further information, please review the OFAC Food Security Fact Sheet: Russia Sanctions and Agricultural Trade
Please see link below for full list of sanctioned entities and individuals.
https://ofac.treasury.gov/recent-actions/20241030 and
https://home.treasury.gov/news/press-releases/jy2700 and
https://ofac.treasury.gov/media/933531/download?inline and
https://ofac.treasury.gov/media/933536/download?inline and
https://ofac.treasury.gov/media/933541/download?inline and
https://ofac.treasury.gov/media/933546/download?inline and
https://ofac.treasury.gov/media/933551/download?inline and
https://ofac.treasury.gov/faqs/1198
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October 31, 2024: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned five Mexican nationals, and two Mexico-based entities linked to La Linea, a violent Mexico-based drug trafficking organization responsible for trafficking fentanyl and other deadly drugs into the United States. This action was coordinated closely with the Drug Enforcement Administration and the Government of Mexico, including La Unidad de Inteligencia Financiera (UIF), Mexico’s Financial Intelligence Unit.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an OFAC Compliance Communiqué: Sanctions Compliance Guidance for the Maritime Shipping Industry to aid maritime sector stakeholders in identifying certain new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance.
The following individuals have been added to OFAC’s SDN List:
- Aguayo, Adrian of Mexico;
- Carrasco Levya, Josefa Yadira of Mexico;
- Nieto Fierro, Heber of Mexico;
- Oretega Gallegos, Jorge Adrian of Mexico; and
- Salas Aguayo, Jesus of Mexico.
The following entities have been added to OFAC’s SDN List:
- Y H. El Remate, Sociedad Anonima De Capital Variable; and
- Soluciones Tecnologicas y Paqueteria Tres, Sociedad Anonima De Capital Variable.
https://ofac.treasury.gov/recent-actions/20241031 and
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