d test, to see if the prices of the exporter's U.S. sales vary significantly across region, time period or purchaser. Use of this test as part of the differential pricing analysis has been subject to much litigation, with the primary point of contention being whether Commerce must satisfy basic statistical assumptions such as roughly equal variances and normally-distributed data sets when running the test.

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Differential Pricing Analysis

The Commerce Department uses a differential pricing analysis to detect whether companies are selling goods across different time periods, regions or purchasers in an effort to mask the dumping of their products into the U.S. market. As part of this analysis, the agency will use a statistical test, called the Cohen's d test, to see if the prices of the exporter's U.S. sales vary significantly across region, time period or purchaser. Use of this test as part of the differential pricing analysis has been subject to much litigation, with the primary point of contention being whether Commerce must satisfy basic statistical assumptions such as roughly equal variances and normally-distributed data sets when running the test.

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Commerce Slaps Export Ban Over Aircraft Equipment Sales to Iran
November 12, 2014 |Commerce Dept.

The Commerce Department slapped a ten-year ban on export privileges for Mohammad Hakin Hashemi for exporting aircraft parts from the U.S. to Iran without a go ahead from the Treasury Department’s Office of Foreign Assets Controls (here). The ban takes effect retroactively on Dec. 16, 2013, the date of Hashemi’s conviction in a California district court. Commerce revoked all licenses granted to Hashemi at the time of his conviction. Hashemi is also barred from any involvement in U.S. export activity. BIS said Hashemi's last known address is in London.

OFAC Adds Individuals, Entity, Makes Deletions to SDN List
November 12, 2014 |Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control added individuals and entity to the
Specially Designated Nationals list, and also deleted several entries.

The following Colombian individuals have been added to OFAC’s SDN List (here):
• Perez Ocampo, German Alberto (Colombia)
• Perez Ocampo, Santiago (Colombia)

The following Yemeni individuals have been added to OFAC’s SDN List (here):
• Al Hakim, Abdullah Yahya (Yemen)
• Al-Huthi, Abd Al-Khaliq (Yemen)
• Saleh, Ali Abdullah (Yemen)

The following Colombia entity has been made to OFAC’s SDN List (here):
• Compra Venta Gerpez (Colombia)

The following deletions have been added to OFAC’s SDN List (here):
• Gomez Rua, Adolfo Leon (Colombia)
• Dolautos Vehiculos E Inmuebles Y Cia (Colombia)
• Taller Ramiautos I.P. (Colombia)
• Digital Comunications Service (Colombia
• Guberek Reyes, David Felipe (Colombia)
• Florez Grajales, Yudy Lorena (Colombia)
• Florez Grajales, Yudi Lorena (Colombia)
• Fiorillo Baptiste, Lester Raul (Colombia)
Comme

OFAC Approves Nearly 100 Licenses for Iran, Sudan Exports in 4th Quarter of 2013
October 28, 2014 |Treasury Dept.

The Treasury Department granted 99 licenses for U.S. agriculture and medical exports to Iran and Sudan, two of the primary countries the Obama administration continues to sanction, in the fourth quarter of calendar year 2013, that agency’s Office of Foreign Assets Control said in recent days (here). OFAC authorizes some U.S. exports of food products, medicine and medical devices under the Trade Sanctions Reform and Export Enforcement Act of 2000. From Oct. 1 through Dec. 31, 2013, OFAC also denied one license, although OFAC didn’t give details on that application. OFAC processed dozens of license amendments and “return-without-action” notices in that time period. The 99 licenses OFAC approved included 18 for agricultural commodities, nine for medicine and 72 for medical devices. Eighty-one out of the 99 licenses authorized shipments to Iran, and the other 18 authorized trade to Sudan. The average wait time for a license approval is 59 business days, while a denial takes on average 160 business days, OFAC said.

BIS Slaps Export Ban on Texas Co. Over Computer Shipments to Iran
October 20, 2014 |Commerce Dept.

The Bureau of Industry and Security eliminated exporting privileges for Texas-based Borna Faizy and Touraj Ghavidel for 10 years, after concluding the two conspired to export computers to Iran from the United States via the United Arab Emirates. The computers, controlled for anti-terrorism purposes, are located on the Commerce Control List and subject to the Iranian Transaction Regulations, BIS said. The two traders used their company Signal Micro Systems to send hundreds the computers to Iran from 2009 to 2011, with a value of more than a million dollars. That company is also barred from participating in the export of goods for 10 years. Faizy was president of Signal Micro Systems during the time the violations were committed, and Ghavidel served as chief operating officer. The two allegedly did not obtain authorization from BIS or Treasury’s Office of Foreign Assets Control.

OFAC Relaxes Sanctions on Russian-Owned Turkish Bank
October 9, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department authorized U.S. citizens and companies to make some transactions with DenizBank, after Executive Order 13662 prohibited dealings with the company. Denizbank is a Turkish financial institution owned by Sberbank, Russia’s largest bank. The U.S. sanctioned Sberbank in September, placing it on the Specially Designated Nationals List (see 14091503). That move was part of a larger sanctions package that followed a number of other rounds of sanctions since the outset of 2014. Treasury’s Office of Foreign Assets Control is also allowing U.S. transactions with banks that Denizbank owns 50 percent or more of. A Treasury directive, under the executive order, bars U.S. individuals or companies from dealings with sanctioned banks in “new debt of longer than 90 days maturity or new equity for these persons, their property, or their interests in property" (here).