Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching the title or by clicking on the hyperlinked reference number.
The Bureau of Industry and Security is considering revising its voluntary self-disclosure review process to focus on “more serious” disclosures, said Matthew Axelrod, BIS’s top enforcement official. Axelrod, speaking during a June 14 Regulations and Procedures Technical Advisory Committee meeting, said the change could better dedicate the agency’s time to VSDs that warrant more attention.
The U.K.'s Department of International Trade released guidance on how to comply with the myriad of trade restrictions and sanctions that apply to British businesses that trade with Russia. The guidance covers sectoral sanctions, export and import bans and licensing, tariffs on Russian and Belarusian goods, financial sanctions and transport sanctions.
A U.K. court ordered Alexander George, a U.K. citizen and former company boss, to pay over $851,000 relating to export control violations, Revenue & Customs announced. George was convicted in 2018 of violating U.K. export controls by exporting fighter jet parts to Iran and sentenced to two and a half years in prison over the illicit scheme. If the defendant fails to pay the court-ordered penalty on time, he will see another three months in prison, Revenue & Customs said, with the fine still due.
A group of European countries not in the EU aligned with a series of sanctions decisions implemented by the bloc relating to Russia and Belarus' invasion of Ukraine and to ISIL (Da'esh) and al-Qaida, the European Council announced. Groups of countries aligned with five recent sanctions moves relating to the war in Ukraine and one recent move over ISIL and al-Qaida.
Japan imposed another wave of sanctions on Russia, laying out an export ban of certain goods used to support industrial infrastructure, the Ministry of Economy, Trade and Industry announced June 10, according to an unofficial translation. The export ban covers wood and wood products, steel storage tanks, hand or processing tools and machines, electrical equipment, trains, bulldozers and trucks. The restrictions will enter into force June 17.
The U.S. this week spoke with China to again warn it about helping Russia avoid international sanctions, a senior administration official said. During a June 13 meeting between U.S. National Security Adviser Jake Sullivan and Chinese Politburo Member Yang Jiechi, Sullivan “reiterated concerns that the United States has raised repeatedly with China with respect to certain kinds of assistance to Russia,” the official said during a call with reporters. Although U.S. officials said they haven’t yet seen signs that China is helping Moscow evade sanctions, the U.S. has publicly and privately warned Beijing it will face severe penalties if it does so, including secondary sanctions and strict export controls (see 2203140009).
The Senate Foreign Relations Committee last week approved a bill that would authorize U.S. sanctions under the Countering America’s Adversaries Through Sanctions Act against anyone who helps Iran acquire unmanned drones or their parts. The bill was overwhelmingly passed by the House in April (see 2204280007).
U.S.-based Hygienic Dress League Corp said it may have violated U.S. sanctions, according to a June 9 SEC filing. The company, which operates in the non-fungible-tokens sector, said it recently submitted a voluntary self-disclosure to the Office of Foreign Assets Control after it may have allowed its software to be downloaded by people or entities located in territories subject to U.S. trade embargoes. After learning of the potential violations, the company began an “internal review” and took “remedial action designed to prevent similar activity from occurring in the future,” the filing said. The disclosure is still under review by OFAC.
Braumiller Law Group released a June 12 “primer” on deemed export control compliance, outlining who may be subject to the controls and what is considered a release of technology, source code and technical data. The post also details several examples of deemed export enforcement actions, saying penalties can be mitigated through voluntary self-disclosures and “proactive compliance measures.”