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 Authorized Transactions on Arrested MV Dianthe
October 31, 2013 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Affairs Control (OFAC) authorized certain transactions related to a Specially Designated Nationals and Blocked Persons list vessel, MV Dianthe, currently under arrest in Mundra, India, according to an Oct. 30 OFAC statement. Such transactions include, but are not limited to, bidding on the purchase of the vessel, paying deposits and providing financing, insurance, or funding in connection with the purchase. In furtherance of the arrest, detention, and judicial sale of the vessel, vessel management service, port agency services, purchasing of bunkers, repairing or modifying the Vessel for commercial use, providing crewing, and hiring surveyors to inspect the vessel are also authorized. This authorization expires on Nov. 14, 2014.

OFAC, KMT Group AB Settle Iran Sanctions Violations Case
October 25, 2013 by Brian Dabbs|Penalties and Courts

The KMT Group AB settled a civil liability case with the Treasury Department Office of Foreign Assets Control (OFAC), agreeing to pay $125,000 for apparent violations of Iranian Transactions and Sanctions Regulations committed by a subsidiary company, said OFAC. The KMT Group AB subsidiary attempted to export nine high pressure water jetting pump units pumps from the U.S. to Germany, with knowledge or reason to know that the goods were intended specifically for reexportation to South Pars Industrial Gas Complex in Tehran, Iran, said OFAC. The attempted export took place between February and March 2009. OFAC said the company did not voluntarily self-disclose the export destination to OFAC, but the violations do not constitute an egregious case, the agency said. CBP already seized two of the pumps and as part of the settlement, the KMT Group AB agreed that no KMT Group entities will contest CBP’s forfeiture proceedings against the remaining seven pumps, OFAC said.

Ameron International Settles with OFAC Over Iran, Cuba Sanctions Violations
October 24, 2013 by Brian Dabbs|Treasury Dept.

The Ameron International Corporation settled a civil liability case with the Treasury Department’s Office of Foreign Assets Control (OFAC) over alleged violations of the Iranian Transactions and Sanctions Regulations and Cuban Assets Control Regulations, agreeing to pay $434,700, OFAC said on Oct. 24. OFAC determined that Ameron did not voluntarily self-disclose to OFAC indirect dealings with Iranian and Cuban interests that occurred from 2005 to 2006. The apparent violations constitute a non-egregious case, OFAC said.

OFAC Announces Penalty for Iran Sanctions Violations
October 22, 2013 by Brian Dabbs|Treasury Dept.

The Treasury Department’s Office of Foreign Assets Control (OFAC) announced on Oct. 21 the assessment of a $1.5 million penalty against UAE-based investment, advising and trading company, Alma Investment, for violating the Iranian Transactions and Sanctions Regulations. The company did not voluntarily self-disclose at least six electronic funds transfers, totaling $103,283, processed through financial institutions located in the United States for the benefit of persons in Iran, OFAC determined. Alma did not have an OFAC compliance program, nor did it cooperate with OFAC during the investigation, said OFAC.

Commerce Issues Penalties for EAR Violations
October 7, 2013 by Brian Dabbs|Commerce Dept.

The Commerce Department’s Bureau of Industry and Security (BIS) announced (here) its intention to initiate administrative proceedings against Afshin Naghibi for 17 violations of the Export Administration Regulations (EAR) committed between 2008 and 2010. Naghibi will be assessed a civil penalty of $800,000 to be paid incrementally. Among other penalties, he is also prohibited from engaging in any export or reexport activities for an unspecified period.

BIS Denies Export Privileges for Export Control Violations
September 30, 2013 by Brian Dabbs|Exports

The Bureau of Industry and Security denied export privileges to three men for violations of the Arms Export Control Act and the International Emergency Economic Powers Act. The three are denied export privileges for up to 10 years of the date of respective convictions. The details follow: