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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OFAC Amends, Expands Syrian Sanctions Regulations
April 9, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) is amending the Syrian Sanctions Regulations and reissuing them in their entirety through a final rule, effective April 10. OFAC is also incorporating new general licenses into the regulations and making other technical changes.

Treasury Expands Licenses for Food, Medical Export to Iran
April 9, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) issued a final rule that amends the Iranian Transactions and Sanctions Regulations to expand licenses that authorize the exportation or reexportation of a broader category of agricultural commodities to individuals and entities in Iran. The rule also adds a new general license that authorizes the exportation or reexportation of certain replacement parts for certain medical devices. The rule was effective April 7. OFAC also posted a list of frequently asked questions (here).

OFAC Settles Civil Case with Sea Tel Over Alleged Iran Sanctions Violations
April 2, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) settled a potential civil liability case with Sea Tel Inc. over alleged violations of the Iranian Transactions and Sanctions Regulations, OFAC said on April 2. Sea Tel agreed to pay $85,113 for allegedly invoicing orders of marine antenna systems to a South Korean distributor that intended to reexport the products to Iran. Sea Tel voluntarily disclosed the action to OFAC, and the apparent violations constitute a non-egregious case, said OFAC.

OFAC Settles Civil Case with GAC Over Fuel Supply for Iran Vessel
April 1, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) settled a potential civil liability case with Houston-based GAC Bunker Fuels. Philadelphia-based partner GAC Shipping agreed to pay the $157,000 penalty on behalf of GAC Bunker Fuels. GAC supplied bunker fuel in Paranagua, Brazil for an Iranian vessel carrying an agricultural commodity, in alleged violation of the Iranian Transactions and Sanctions Regulations. GAC did not voluntarily disclose the fuel supply, but OFAC does not consider the violation egregious.

OFAC Adds Individual to SDN List
March 26, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) added the following individual to the Specially Designated Nationals (SDN) list on March 26: