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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BIS, OFAC Continue Sanctions Campaign Against Russian Defense, Other Sectors
September 15, 2014 by Brian Dabbs|White House

The Bureau of Industry and Security furthered its crackdown on Russian arms and weaponry traders on Sept. 12, as the Obama administration strapped another sanctions package on the Russian defense, financial and energy sectors (here). BIS added five Russian companies to its Entity List. The designations level license requirements, with a presumption of denial, for the export, reexport and foreign transfer of items subject to the Export Administration Regulations (EAR). Those companies are as follows:

State Slaps Terrorist Designation on Syrian National
September 5, 2014 by Brian Dabbs|State Department

The State Department designated Syrian national Abu Mohammed al-Adnani, along with a slew of aliases, as a Specially Designated Global Terrorist. The designation includes prohibitions against knowingly providing, attempting or conspiring to provide material support or resources or engaging in transactions with the individual. The designations also freeze all property and interests of the entity in the U.S. or in the control of U.S. citizens. Al-Adnani is active in Islamist groups involved in the Syrian conflict, State says (here). The Treasury Department's Office of Foreign Assets Control sanctioned Al-Adnani in mid-August (see 14082012).

OFAC Settles Case with Citigroup Over Iran Sanctions, SDN List Transfer Violations
September 4, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control settled a civil case with Citigroup Inc. over multiple alleged violations of four sanctions laws, including involvement in the shipment of sanctioned goods to Iran, OFAC said on Sept. 3. Citigroup agreed to pay OFAC $217,841 for alleged violations of the Iranian Transactions and Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Foreign Narcotics Kingpin Sanctions Regulations and the Global Terrorism Sanctions Regulations. Citigroup Trade Services Malaysia allegedly processed in 2009 four export bill collection applications on behalf of Citibank N.A., Hong Kong that involved goods shipments to Iran, including to the Islamic Republic of Iran Shipping Lines, which has been specifically targeted by OFAC for sanctions in recent years. Citibank also processed payments between 2011 and 2012 to individuals on the Specially Designated Nationals List, OFAC said.

Obama Administration Places Multitude of Iran-Related Entities on SDN List
August 29, 2014 by Brian Dabbs|White House

The Treasury and State Departments on Aug. 29 released an extensive list of sanctions on individuals and entities in Iran. Treasury’s Office of Foreign Assets Control (OFAC) placed individuals, entities and vessels on the Specially Designated Nationals (SDN) List. National Security Council spokeswoman Caitlin Hayden said in a statement the Iran sanctions are consistent with the relief package brokered between P5+1 countries and Iran in January (see 14072525). “Our actions today and since the start of the talks are consistent with our commitments under the Joint Plan of Action, which provided limited relief of certain sanctions in exchange for Iranian steps that halted its nuclear program and rolled it back in key respects,” said Hayden.

OFAC Sets Limits on Use of Sanctions List Search Tool
August 26, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control is now “managing” the number of searches users conduct on the Sanctions List Search tool within a limited period of time in order to ensure all users have a “similar search experience.” OFAC did not specify the number of searches permitted or the search timeframe involved, but said it will temporarily suspend for a brief time search access for users that exceed the number of searches permitted. Most users won’t notice a change, said OFAC.