There are “significant gaps” in private sector knowledge on North Korea and Iran sanctions compliance and implementation, according to a Feb. 6 report by the Royal United Services Institute and the Association of Certified Anti-Money Laundering Specialists. The report, based on more than 350 responses to a survey sent to the finance industry, shows that large, international banks have a greater grasp of sanctions compliance than local and national banks, which are more often “being exploited” by proliferators. The report also said that U.S. banks are most vulnerable to proliferation risks from Iran and that “few banks” consult the United Nations Panel of Experts reports on North Korea.
An Iranian citizen who was head of a Dubai-based export company was sentenced to time served and fined $5,000 for illegally exporting gas turbine parts to Iran, the Justice Department said in a Jan. 30 press release. Mahin Mojtahedzadeh pleaded guilty to violating the International Emergency Economic Powers Act and Iran sanctions in July 2019 after using her company, ETCO-FZC, to evade U.S. sanctions against Iran (see 1907190040). Mojtahedzadeh, who has been held in custody since November 2018, will be transferred to immigration custody and be removed from the U.S., the Justice Department said.
The first humanitarian exports were sent through the joint mechanism created by the Treasury and State departments nearly three months after the channel was created (see 1910250057), Treasury said Jan. 30. Treasury said the mechanism successfully facilitated transactions from a “humanitarian channel” in Switzerland that sent cancer and transplant-related drugs to Iranian medical patients. The channel is subject to “strict due diligence measures,” Treasury said, adding that the successful transactions prove “a model for facilitating further humanitarian exports to Iran.”
The State Department issued a list of materials that constitute “raw or semi-finished metals” under the Iran Freedom and Counter-Proliferation Act, according to a notice. The list includes more than 60 types of metals. The IFCA expands the scope of sanctions on Iranian energy and shipping sectors as well as a range of ports.
The Treasury’s Office of Foreign Assets Control has done little to define the broad scope of the Iranian executive order issued earlier this month that expanded sanctions authority for the Treasury and State departments, according to trade lawyers. The order (see 2001100050) -- which authorized both primary and secondary sanctions against Iran’s construction, mining, manufacturing and textiles sectors -- did not define the scope of the Iranian sectors that may be subject to sanctions, and OFAC has yet to release guidance. OFAC did, however, issue a frequently asked question that provided a 90-day wind-down period (see 2001160011).
The United Kingdom, France and Germany plan to trigger the dispute settlement mechanism of the Joint Comprehensive Plan of Action, potentially leading to European snapback sanctions against Iran. In a Jan. 14 statement, German Foreign Minister Heiko Maas said the three countries still want to preserve the agreement, but “we could no longer leave the growing Iranian violations of the nuclear agreement unanswered,” Maas said, according to an unofficial translation. “We will tackle this together with all partners in the agreement. We call on Iran to participate constructively in the negotiation process that is now beginning.”
Export Compliance Daily is providing readers with some of the top stories for Jan. 6-10 in case you missed them.
The Uni, Germany and France said they remain committed to the Joint Comprehensive Plan of Action, again urged Iran to return to the deal and expressed concerned with U.S. sanctions. “We have made clear our regret and concern at the decision by the United States to withdraw from the JCPoA and to re-impose sanctions on Iran,” the countries said in a Jan. 12 joint statement. “Despite increasingly difficult circumstances, we have worked hard to preserve the agreement … it is essential that Iran return to full compliance with its commitments.”
China’s Foreign Ministry criticized the U.S.’s decision to impose more Iran sanctions last week, saying the measures, which affected some Chinese entities, should be reversed. Along with Iranian officials and metal companies, the U.S. sanctions targeted a Beijing-based company for buying Iranian steel and a China-based company for managing a vessel that transported the steel (see 2001100050). “We urge the U.S. to cease immediately the wrongful sanctions on Chinese businesses,” a ministry spokesman said during a Jan. 13 press conference. “We will continue to staunchly defend Chinese enterprises' legitimate rights and interests.” China said it has been dealing with Iran for a “long time” and “such cooperation, which is justified and lawful and doesn't harm any third party's interests, should be respected and protected.”
President Donald Trump issued an executive order expanding U.S. sanctions authority against Iran and the Treasury Department announced a series of new Iran sanctions, including measures against senior Iranian officials, metal companies and a vessel. The executive order grants the U.S. the authority to impose a series of new primary and secondary sanctions against people and companies involved with Iran’s construction, mining, manufacturing and textiles sectors, Treasury Secretary Steven Mnuchin said during a Jan. 10 press conference. While the executive order only mentioned those four sectors, additional Iranian sectors may be sanctioned, Mnuchin said.