Iran Export Controls

The Bureau of Industry and Security on Oct. 23 will add 26 companies and people to the Entity List for trying to buy controlled U.S. items for China’s military, evade sanctions against Russia, supply sensitive goods to Iran or Pakistan, or for evading U.S. end-use checks, the agency said in a final rule released Oct. 21. BIS will also remove two entities from the list and update the address information for another entity.

The U.S. is increasingly expecting companies to monitor government guidance as well as export violations committed by others, and to use those cases as “lessons learned” to improve their own compliance programs, lawyers said this week.

The Office of Foreign Assets Control this week sanctioned several China-based companies, a person in Iran and others for helping to move weapons, dual-use items or commercial goods in support of the Houthis, the Yemen-based group that the U.S. designated as a terrorist organization in January (see 2401170025).

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.

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.