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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Companies Charged with OFAC Violations
February 25, 2013 by Jessica Arriens|Treasury Dept.

The Bank of Guam and a California scrap metal company agreed to civil liability payments for violations of Treasury Department's Office of Foreign Asset Control, the office said Feb. 22.

Calif. Firm to Pay $404,100 on Charges of Illegal Exports to Iran
February 21, 2013 by Mike Feazel|Treasury Dept.

American Optisurgical, Inc., of Lake Forest, Calif., agreed to pay $404,100 to settle potential civil liability for alleged violations of the Iranian Transactions and Sanctions Regulations from 2005 to 2010, said the Treasury Department's Office of Foreign Assets Control. It said AOI violated the ITSR on 36 occasions when it exported, or attempted to export, unlicensed medical goods and services to Iran, or to a person in a third country who knew or should have known that the medical goods and services were intended for Iran. OFAC also alleged that AOI violated the RPPR when it failed to fully respond to two Administrative Subpoenas issued to AOI by OFAC. The alleged violations involved transactions valued at $202,765, OFAC said. It said AOI didn't voluntarily self-disclose the matter to OFAC, but the alleged violations constituted a non-egregious case. It said AOI's alleged violations resulted from willful or reckless conduct; AOI's senior management was directly involved in the willful or reckless conduct; AOI actively participated in concealing the ultimate destination of its exports to Iran; AOI continued to export unlicensed medical goods to Iran even after having received two Administrative Subpoenas from OFAC regarding its conduct; AOI is a commercially sophisticated entity; AOI has not been the subject of prior OFAC enforcement action; the exports at issue likely would have been licensed by OFAC under existing licensing policy; and, AOI agreed to toll the statute of limitations.

International Trade Today Calendar
February 15, 2013 by Mike Feazel|Trade Calendar

Feb. 20 International Trade Administration Renewable Energy and Energy Efficiency Advisory Committee meets, 9:30 a.m., in Washington, D.C. -- http://www.ofr.gov/OFRUpload/OFRData/2013-00668_PI.pdf

U.S. Economic Sanctions Hurt U.S. Businesses by Creating Uncertainty, Varying Rules, Says NFTC Head
February 15, 2013 by Mike Feazel|Exports

U.S. policy on economic sanctions against countries like Iran "has created enormous uncertainty in the exporting community and among banks," said Bill Reinsch, president of the National Foreign Trade Council, in a speech at the Georgetown University Law Center Feb. 14. He said companies with export licenses to such countries "find it difficult to obtain financing for their exports because banks find it easier to avoid all transactions with Iran rather than trying to distinguish between the 'good' ones and the 'bad' ones, even though the former are documented with a government license."

OFAC Migrating SDN List to New Server
February 13, 2013 by Mike Feazel|Treasury Dept.

The Treasury Department's Office of Foreign Assets Control will migrate its Specially Designated Nationals List data (and other sanctions-related information) that it maintains on its OFACFTP.TREAS.GOV server to a new location about Feb. 22, it said. As a result, the IP address for that content will change.