The Office of Foreign Assets Control this week designated Iran’s Islamic Revolutionary Guard Corps Cooperative Foundation along with five of its board members, Iran's deputy minister of intelligence and security, and four senior IRGC commanders.
OFAC sanction activity
Jason Prince, former chief counsel at the Treasury Department's Office of Foreign Assets Control, has moved to Crowell & Moring as a partner, the firm announced. He will advise clients on sanctions and export controls imposed on Russia and other nations and parties. During his time at OFAC, Prince "oversaw the legal design of new sanctions measures and led the legal review of all major OFAC enforcement, compliance, licensing, litigation, and regulatory actions," the firm said.
Sharath Patil, former associate attorney at Diaz Trade Law, has joined the Treasury Department's Office of Foreign Assets Control as a sanctions enforcement officer, according to his LinkedIn page. Before working at Diaz Trade Law, Patil was research director for international trade at the nonprofit advocacy group Public Citizen.
The Office of Foreign Assets Control is adjusting its civil monetary penalties for inflation, the agency said in a notice. The new amounts include higher maximum penalties for violations of the Trading With the Enemy Act, the International Emergency Economic Powers Act, the Antiterrorism and Effective Death Penalty Act, the Foreign Narcotics Kingpin Designation Act and the Clean Diamond Trade Act. The agency also updated two references to “one-half the IEEPA maximum CMP from $165,474 to $178,290” and adjusted the record-keeping CMPs in OFAC’s Economic Sanctions Enforcement Guidelines. The changes take effect Jan. 13.
The Office of Foreign Assets Control this week renewed a general license that authorizes certain transactions related to safety and environmental measures for certain sanctioned vessels. General License 21B, which replaces GL 21A, is valid through 12:01 a.m. April 13. The license was scheduled to expire Jan. 14 (see 2212140028)). OFAC also updated Frequently Asked Question 1097 to reflect the update.
Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in staying up to date with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2022.
The Office of Foreign Assets Control Dec. 30 fined a multinational Danish-based refrigeration manufacturer more than $4.3 million for violating U.S. sanctions against Iran, Syria and Sudan. Danfoss, which also sells air conditioners and other cooling and heating products, illegally directed customers in all three countries to make payments through a U.S. financial institution, OFAC said in an enforcement notice. The company also made illegal payments to entities in Iran and Syria.
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The Office of Foreign Assets Control this week issued Venezuela-related General License 31B, which replaces General License 31A (see 2101040025), authorizes U.S. persons to engage in transactions otherwise prohibited by sanctions involving the Venezuelan National Assembly seated on Jan. 5, 2016, and associated entities and people. The new license removes a reference to Venezuelan opposition leader Juan Guaido, since he was ousted by the opposition party's National Assembly last month. OFAC also amended five frequently asked questions related to the license and the Venezeula sanctions.
The Office of Foreign Assets Control added seven people to its Specially Designated Nationals List in connection with Iranian unmanned aerial vehicle shipments to Russia, it said in a Jan. 6 news release. The designees are six executives and board members of previously designated Qods Aviation Industries (QAI), an Iranian defense manufacturer that designs and produces UAVs being transferred to Russia for use in Ukraine. OFAC also sanctioned the director of Iran’s Aerospace Industries Organization, the "key organization responsible for overseeing Iran’s ballistic missile programs." The agency also updated QAI’s entry on the SDN List to include its new alias, Light Airplanes Design and Manufacturing Industries.