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 Publishes Guidance on Iran Sanctions Relief
January 21, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) published on Jan. 20 guidance for Iran sanctions relief in order to implement the joint plan of action (JPOA), brokered between Iran and P5+1 countries on Nov. 24, 2013. The sanctions relief will take place from Jan. 20 to July 20, and the U.S. retains the right to scale back the relief in the event of JPOA violation. With the exception of certain civil aviation and humanitarian activities, the sanctions relief does not apply to U.S. persons or foreign entities owned or controlled by U.S. persons that are otherwise subject to the Iranian Transactions and Sanctions Regulations. or other related U.S. sanctions law. The relief does not involve persons on the OFAC Specially Designated Nationals and Blocked Persons lists, unless otherwise noted, OFAC said. The relief lifts sanctions in the following areas:

OFAC Adds Entities to SDN List
January 14, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) added entities to the Specially Designated Nationals (SDN) list on Jan. 10. The State Department also designated on Jan. 10 the following entities as separate Foreign Terrorist Organizations and Specially Designated Global Terrorists (see 14011015).

OFAC Adds Individuals and Entities to SDN List
January 13, 2014 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) added individuals and entities to the Specially Designated Nationals (SDN) list on Jan. 10. The State Department also designated on Jan. 10 the following individuals as Specially Designated Global Terrorists and the following entities as separate Foreign Terrorist Organizations and Specially Designated Global Terrorist entities (see 14011015).

State, OFAC Designate Qari Saifullah Specially Designated Global Terrorist, Specially Designated National
January 7, 2014 by Brian Dabbs|State Department

The State Department on Jan. 7 designated (here) Qari Saifullah a Specially Designated Global Terrorist for organizing and ordering terrorist activities in Afghanistan. U.S. citizens are now prohibited from engaging in transactions with Saifullah. State, in consultation with the Justice and Treasury Departments, froze all Saifullah’s property and interests. The Treasury Department’s Office of Foreign Assets Control also placed (here) Saifullah on the Specially Designated Nationals List.

OFAC Adds Individuals to SDN List
December 20, 2013 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) added individuals to the Specially Designated Nationals (SDN) list on Dec. 19 for affiliation with transnational criminal organizations.

HSBC Bank USA Settles OFAC Case Involving SDN Financial Transactions
December 18, 2013 by Brian Dabbs|Treasury Dept.

HSBC Bank USA (“HBUS”) will remit $32,400 to the Treasury Department’s Office of Foreign Assets Control (OFAC) to settle a potential civil liability case over three apparent violations of the Global Terrorism Sanctions Regulations, OFAC said on Dec. 17. HBUS facilitated financial transactions involving an individual and entity on the Specially Designated Nationals and Blocked Persons List, OFAC said. HBUS voluntarily self-disclosed the apparent violations to OFAC, OFAC determined, adding that the violations did not constitute an egregious case.