The departments of State and the Treasury, along with the U.S. attorney general, announced sanctions against an Iranian man for contributing to “proliferation of weapons of mass destruction or their means of delivery,” according to a notice to be published in the April 10 Federal Register. State said Reza Ebrahimi is being designated under a 2005 Executive Order titled “Blocking Property of Weapons of Mass Destruction Proliferators and Their Supporters.” The designation took effect March 22, 2019.
Export Compliance Daily is providing readers with some of the top stories for April 1-5 in case they were missed.
Treasury’s Office of Foreign Assets Control announced two settlements totaling more than $650 million with a United Kingdom-based bank that allegedly violated U.S.-imposed sanctions on Cuba, Iran, Syria, Zimbabwe and now-repealed sanctions on Myanmar and Sudan, OFAC said in an April 9 notice. The announcement marked OFAC’s largest settlement amount since June 2014, when the agency reached a $963 million settlement with a bank that also violated sanctions on Cuba, Iran, Myanmar and Sudan.
In the April 8 edition of the Official Journal of the European Union the following trade-related notices were posted:
The U.S. designated the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization, marking the first time the U.S. has labeled a government an FTO, according to an April 8 White House notice. The designation is designed to increase financial pressure on Iran and isolate it from military resources, which the notice said are used for “terrorist activities.” The designation will take effect April 15, according to a statement made at a State Department briefing April 8 by Assistant Secretary of State for Counterterrorism Nathan Sales: "With the announcement today, which will take effect a week from now, the legal status of the IRGC will change from an organization to a designated foreign terrorist organization."
The Trump administration is expected to complete a review of the current scope of U.S. export controls on countries subject to arms embargoes, including China, and may make potential regulatory changes by May 10, according to an April 5 blog post from Steptoe & Johnson. The administration’s review stems from a section of the 2018 Export Control Reform Act, which requires a “review relating to countries subject to comprehensive United States arms embargo.” The act specifically requires the Commerce, State and Defense departments, among others, to review export controls on trades with “military end uses and military end users,” according to the post.
In the April 5 edition of the Official Journal of the European Union the following trade-related notices were posted:
The Treasury's Office of Foreign Assets Control sanctioned two oil companies operating in the Venezuelan oil sector and identified 34 ships associated with Petróleos de Venezuela (PdVSA), according to an April 5 press release. OFAC identified the two shipping companies as Liberia-based Ballito Bay Shipping Incorporated and Greece-based ProPer In Management Incorporated, and said one or both transported oil from Venezuela to Cuba during February and March using an oil tanker called Despina Andrianna. OFAC also named the 34 ships that are “blocked property” of PdVSA, a Venezuela state-run oil company sanctioned by the U.S.
The Treasury’s Office of Terrorism and Financial Intelligence is requesting a nearly $25 million budget increase from the previous year, partly to help with staffing concerns, according to Treasury’s annual budget report. OTFI lists its “increasing role” in the Trump administration as justification for the increased budget. The agency is requesting about $165 million.
Treasury’s March settlement with Stanley Black & Decker serves as a compliance guide for U.S. companies and represents an important peek into how the Treasury's Office of Foreign Assets Control plans to issue enforcement settlements throughout 2019, according to an April 1 report by WilmerHale.