John Unsalan, the president of building materials supplier Metalhouse, was arrested and charged with violating U.S. sanctions on oligarch Sergey Kurchenko and two of Kurchenko's companies by providing them with over $150 million for steel-making materials, DOJ announced April 17. Unsalan faces 10 counts of violating the International Emergency Economic Powers Act, one count of conspiring to evade U.S. sanctions, one count of conspiring to commit international money laundering and 10 counts of international money laundering, each of which comes with a maximum 10-year prison sentence.
The Bureau of Industry and Security again renewed the temporary denial order for Moscow-based air cargo carrier Aviastar. BIS first suspended the export privileges of the Russian cargo charter airline in April 2022 (see 2204210043) and renewed the order in October (see 2210190009), barring it from participating in transactions with items subject to the Export Administration Regulations. The agency renewed the denial order for another 180 days April 14 after finding Aviastar continued to illegally operate aircraft subject to the EAR, including for flights within Russia.
The Bureau of Industry and Security recently suspended the export privileges of four people, including two for making false statements to the government and two others for illegally exporting guns or ammunition to Mexico.
The Bureau of Industry and Security this week renewed the temporary denial order for Russian airline Ural Airlines, whose export privileges were suspended for 180 days in October after BIS said it violated U.S. export controls by flying multiple aircraft to Russia without required licenses (see 2210170009). BIS said Ural continues to fly planes in violation of the Export Administration Regulations, including flights within Russia and to and from Kyrgyzstan and Tajikistan. The agency renewed the order for another 180 days from April 10.
Niloufar Bahadorifar, a U.S. citizen originally from Iran, was sentenced to four years in prison for conspiring to violate U.S. sanctions on Iran by providing financial services to the Iranian government and for structuring cash deposits, DOJ announced. The Irvine, California, resident was found guilty of conspiring to violate the International Emergency Economic Powers Act.
A recent announcement by DOJ that revises how it assesses corporate compliance programs’ approach to communications platforms (see 2303030056) may be “impractical” and “could threaten the more important, everyday work being done by compliance departments,” said Billy Jacobson, former assistant chief for Foreign Corrupt Practices Act Enforcement at DOJ. Although the revised policies seek to update the criteria the agency uses in its Evaluation of Corporate Compliance Programs guidance document to take into account a company’s approach to messaging applications -- including WhatsApp -- they may not work well in practice, Jacobson said.
Companies should expect the U.S. to devote “higher budgets” and increase interagency coordination to bolster U.S. sanctions and export control enforcement, which could lead to “previously unseen” compliance risks, Orrick said in a recent client alert. The firm pointed to DOJ’s plans to hire new export control and sanctions prosecutors (see 2303070023), the administration’s new disruptive technology strike force (see 2303220037), the joint compliance alert earlier this year that outlines methods Russia uses to circumvent trade restrictions (see 2303020054), and more.
The U.S. District Court for the District of Connecticut ordered Estonia-based exporter By Trade OU to forfeit about $826,000 in connection with the attempted export of a dual-use export-controlled item to Russia, DOJ announced. The company, along with a Latvia-based corporation, conspired to ship a jig grinder made in Connecticut to Russia.
DOJ is seeking the forfeiture of over 1 million rounds of ammunition, thousands of proximity fuses for rocket-propelled grenades and thousands of pounds of propellant for rocket-propelled grenades that it said the U.S. Navy seized en route to militant groups in Yemen from Iran's Islamic Revolutionary Guard Corps. Filing a complaint March 31 in the U.S. District Court for the District of Columbia, DOJ said the action is part of an effort "to enforce U.S. sanctions against the IRGC and the Iranian regime" and the claims are "merely allegations."
The former head of cryptocurrency exchange FTX, Sam Bankman-Fried, pleaded not guilty on March 30 during a proceeding at the U.S. District Court for the Southern District of New York to bribing Chinese authorities, Reuters reported. The bribery charge, filed as a violation of the Foreign Corrupt Practices Act, was added to Bankman-Fried's indictment this week and alleges that the former executive paid around $40 million in cryptocurrency to one or more Chinese government officials to "induce them" to unfreeze certain cryptocurrency trading accounts held by Alameda Research, one of Bankman-Fried's other companies (see 2303280037) (U.S. v. Samuel Bankman-Fried, S.D.N.Y. # 22-00673).