Members of the European Parliament approved a resolution last week calling on the EU to expand sanctions against Russia, Belarus, and non-EU countries and entities providing Russia with military and dual-use technologies.
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.
Companies should continue to expect an “aggressive” U.S. sanctions enforcement landscape heading into next year, and should consider increasing the amount of due diligence they undertake if they haven’t already, panelists said during an event last week about sanctions compliance.
President Joe Biden formally directed his administration last week to implement several new sanctions-related laws, including one aimed at Iranian oil exports.
Sens. Marco Rubio, R-Fla., and Jeff Merkley, D-Ore., introduced a bill Sept. 12 that would require the Commerce, Defense and Treasury departments to notify each other when adding a foreign entity or person to an export control or sanctions list. The proposed Sanctions Lists Harmonization Act is intended to improve coordination among the agencies and “prevent bad actors, such as Communist China, Russia and Iran, from taking advantage of a disjointed policy,” Rubio said. The measure, which was referred to the Senate Banking Committee, is a companion to a bill the House passed Sept. 9 (see 2409100024).
The Treasury Department this week sanctioned 10 people and six entities in Iran and Russia involved in trading Iranian weapons and drones, along with four vessels delivering those shipments. The State Department also designated various shipping companies and vessels, including Iran Air, which the agency said is being used to move Western-origin goods to Russia.
The House approved several export control-related bills late Sept. 9, including the Remote Access Security Act, which is designed to close a loophole that has allowed China to use cloud service providers to access advanced U.S. computing chips remotely (see 2409040046).
Nearly a quarter of the 123 new entries the Bureau of Industry and Security will add to its Entity List this week are Chinese suppliers that the agency named in private red-flag letters to U.S. companies earlier this year.
The Bureau of Industry and Security will add 123 entities to the Entity List, expand the scope of its Russia/Belarus-Military End User Foreign-Direct Product rule, add export controls on certain computer numerical control (CNC) machine tools-related software, and makes corrections to the agency’s Russia and Belarus controls, the agency said in two rules released Aug. 23. The Entity List and FDP rule updates take effect Aug. 27, and the new CNC controls and other corrections take effect Sept. 16.
Trade groups, lawyers, investment firms, technology companies and foreign governments suggested a range of changes to the Treasury Department’s proposed outbound investment rules (see 2406210034), echoing calls last year for more clarity surrounding the due-diligence steps that will be required of deal-makers and warning that the U.S. risks chilling a broad range of U.S. ventures in China (see 2310050035). Several commenters also urged the Biden administration not to finalize the new prohibitions without similar buy-in from allies, with at least one group suggesting the U.S. is further from coordinating the rules among trading partners than it has let on.
A U.S. digital assets company and a European aerospace firm recently disclosed in financial statements that they're under investigation for possible violations of sanctions or export control laws, while an American entertainment company revealed it submitted a sanctions disclosure to the U.S. government.