The State Department issued notices of its report to Congress under the Iran Freedom and Counter-Proliferation Act, which requires the State and Treasury Departments to assess where Iran is buying sensitive materials for its nuclear program and which sectors of its economy are being controlled by the country’s military.
Iran Export Controls
Certain items on the Commerce Control List require a license from BIS to export them to Iran. The Iranian Transactions Sanctions Regulations (ITSR) (31 CFR Part 560) also prohibit the export and reexport of goods to Iran subject to EAR.
A U.S. electronics and computer component company may have violated U.S. sanctions on Iran and Syria, the company said in a Nov. 7 filing with the Securities and Exchange Commission. Colorado-based Arrow Electronics said a “limited number of non-executive employees … facilitated product shipment” to customers for re-export to people covered by U.S. sanctions on Iran and Syria. The transactions took place between 2015 and 2019 and were valued at about $5,000, the company said. Arrow Electronics said it voluntarily disclosed the potential violations to the Treasury’s Office of Foreign Assets Controls and the Commerce Department Bureau of Industry and Security earlier this year. It also disciplined or fired employees involved in the transactions and said it plans to “cooperate fully” with BIS and OFAC. The company said it is not able to “estimate” the potential penalty it may receive.
The Bureau of Industry and Security updated its Entity List by adding 22 entities, updating one entry and removing three entries, BIS said. The added entities include freight forwarding and logistics companies and a medical instrument supplier.
The Treasury’s Office of Foreign Assets Control released quarterly reports of licensing activities for certain authorizations to Iran and Sudan from January through September 2018, OFAC said in a Nov. 5 notice. The report provides information on license applications for exports of agricultural commodities, medicine, and medical devices to Iran and Sudan under the licensing regime in the Trade Sanctions Reform and Export Enforcement Act of 2000, OFAC said. The reports contain statistics on the number of license applications and licenses issued for each product, the number of applications and licenses issued for each country and more.
Export Compliance Daily is providing readers with some of the top stories for Oct. 21-25 in case they were missed.
The Treasury Department announced a mechanism to help companies ensure their humanitarian exports to Iran will not be diverted to the government and other sanctioned Iranian entities, Treasury said in an Oct. 25 press release. The mechanism will require participating foreign governments and financial institutions to “conduct enhanced due diligence” -- including the reporting of “a substantial and unprecedented amount of information” -- on a monthly basis. Treasury’s Office of Foreign Assets Control also issued a guidance outlining the requirements.
Former National Security Adviser John Bolton said U.S. sanctions are not being enforced effectively and criticized what he said is a lack of U.S. involvement in the Japan-South Korea trade dispute.
The Treasury’s Office of Foreign Assets Control announced sanctions on a shipping network that moves hundreds of millions of dollars of oil for Iran, Treasury said in a Sept. 4 press release. The network includes dozens of ship managers, ships and “facilitators” overseen by Rostam Qasemi, a senior Iranian military official and the country’s former minister of petroleum. The sanctions target 16 entities, 10 people and 11 ships.
The Treasury’s Office of Foreign Assets Control sanctioned an oil tanker that shipped more than 2 million barrels of Iranian crude oil to aid Iran’s Islamic Revolutionary Guard Corps-Qods Force, Treasury said in an Aug. 30 press release. The tanker, Adrian Darya 1, and its captain, Akhilesh Kumar, are being sanctioned for providing support to terrorism, Treasury said. Treasury said the IRGC-QF’s “highest-ranking officials” oversee exports of Iran’s oil and hide its origin, sending it to Syria or “IRGC-QF proxies across the region.” The ship, formerly known as Grace 1, was recently detained by Gibraltar and released over U.S. objections (see 1908190036).
The Treasury’s Office of Foreign Assets Control sanctioned five entities and five people for their involvement in procurement networks for Iran’s military, Treasury said in an Aug. 28 press release. The sanctions target two major networks led by Iranian nationals Hamed Dehghan and Seyed Hossein Shariat.