Several companies recently disclosed potential export control or sanctions violations or updated the status of their current disclosures, including several technology businesses, a pharmaceutical company and a cryptocurrency software platform company. The disclosures describe potential violations of U.S. sanctions against several countries -- including Russia, Iran and North Korea -- and one company receiving a no-action letter from the Office of Foreign Assets Control.
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.
Canada and Australia last week announced a range of new Russia-related sanctions to mark the two-year anniversary of Russia’s invasion of Ukraine.
The U.S. announced a new set of sweeping Russia-related export controls and sanctions last week to mark the two-year anniversary of Moscow’s invasion of Ukraine and to respond to Russian opposition figure Alexei Navalny's death in prison. The measures include nearly 100 additions to the Commerce Department’s Entity List, more than 500 sanctions designations by the Treasury and State departments and new government guidance, including a new business advisory to warn companies about Russia-related compliance risks.
The U.S. will announce "major" new sanctions against Russia this week, President Joe Biden told reporters Feb. 20 before leaving on a campaign trip. He said his administration will be releasing new sanctions on Russia as part of a package that will be announced Feb. 23.
The U.S. this week sanctioned four entities and three people for procuring and facilitating the illegal export of “goods and technology from over two dozen U.S. companies” to Iranian end-users, including the Central Bank of Iran.
A New York freight forwarder agreed to complete export compliance training, but won’t face a fine, after admitting to the Bureau of Industry and Security that it illegally shipped enterprise servers and switches to Iran on behalf of an Iran-based exporter.
U.S. enforcement officials last week continued to warn about upcoming export control penalties, saying they hope those cases encourage companies to devote more resources to their compliance programs.
The House Foreign Affairs Committee on Feb. 6 approved a bill that would designate the Houthis as a Foreign Terrorist Organization following the Yemen-based group’s recent attacks on commercial ships in the Red Sea.
The U.S. charged four Chinese nationals this week for their parts in a yearslong conspiracy to violate export controls by smuggling electronic parts through China and to Iran.
The Bureau of Industry and Security will likely issue more penalty announcements this year for export control violations, a former senior BIS enforcement official said, suggesting the current state of enforcement is unprecedented.