Iran Export Controls

Export Compliance Daily is providing readers with some of the top stories for Aug. 19-23 in case they were missed.

The Treasury’s Office of Foreign Assets Control released its Biennial Report on Licensing Activities detailing license applications the agency processed for authorization to export to Iran and Sudan. The Aug. 19 report, which covers OFAC actions from October 2014 to September 2016, is mandated by the Trade Sanctions Reform and Export Enhancement Act of 2000 and covers OFAC applications that request permission to export “agricultural commodities, medicine and medical devices” to Iran and Sudan. The report includes the number of applications OFAC received, issued and denied. OFAC requested public comments on the TSRA’s licensing procedures in 2018 and said it received one comment that pointed to the “difficulties in using the financial mechanisms in place for making payments related to transactions” under the TSRA.

Export Compliance Daily is providing readers with some of the top stories for Aug. 5-9 in case they were missed.

An Iranian citizen pleaded guilty Aug. 9 to conspiring to illegally export technology from the U.S. to Iran, the Justice Department said in a press release. Negar Ghodskani was arrested for the violations in 2017.

The Treasury's Office of Foreign Assets Control found a U.S. company in violation of OFAC’s Reporting, Procedures and Penalties Regulations for failing to provide information about a sale to Iran after being subpoenaed, OFAC said in an Aug. 8 enforcement notice. The violations stem from Southern Cross Aviation’s sale of helicopters to an Iranian businessman in Ecuador, OFAC said.

The Treasury’s Office of Foreign Assets Control sanctioned a “network of front companies and agents involved” in procuring enriched uranium for Iran’s nuclear program, Treasury said in a July 18 press release. The entities and people are based in Iran, China and Belgium and worked as a “procurement network” for Iran’s Centrifuge Technology Company, which produces centrifuges in facilities belonging to the Atomic Energy Organization of Iran, Treasury said.

Commerce denied export privileges for two Iranian nationals and their company after they tried to export a $15,000 micro drill press from the U.S. to Iran, Commerce’s Bureau of Industry and Security said in a July 8 denied export order. Commerce also fined them $300,000 for trying to violate the Export Administration Regulations and the Iranian Transactions and Sanctions Regulations.

Export Compliance Daily is providing readers with some of the top stories for June 24-28 in case they were missed.

A Senate bill introduced June 13 with bipartisan support would require the Trump administration to submit reports to Congress on whether Hong Kong is following U.S. export control laws and sanctions. The requirement, part of a bill that would amend the Hong Kong Policy Act of 1992, would order the Treasury, State and Commerce secretaries to send several House and Senate committees a report on whether Hong Kong has enforced U.S. export controls with respect to “sensitive dual-use items” and abided by both U.S. and United Nations sanctions. The administration would need to submit the reports within 180 days after the enactment of the bill, which was introduced by Sen. Marco Rubio, R-Fla.

The Treasury’s Office of Foreign Assets Control sanctioned the Persian Gulf Petrochemical Industries Company (PGPIC), Iran’s “largest and most profitable petrochemical holding group,” as well as 39 of its subsidiaries, Treasury said in a June 7 press release. PGPIC was sanctioned for funding Khatam al-Anbiya Construction Headquarters, which Treasury said is the “engineering conglomerate” of the Islamic Revolutionary Guard Corps.