Iran Export Controls

A new Defense Department policy memo and guidance on foreign influence within American research institutions could exacerbate already complex export control due diligence challenges at universities, said Jackson Wood, director for industry strategy at Descartes. It also could lead to larger compliance risks for universities pursuing DOD-funded research, said Kit Conklin of compliance risk advisory firm Kharon.

A bill was introduced in the House that could lead to new export controls on genetic mapping technology and sanction entities in China and elsewhere involved in certain genetic mapping efforts. The bill would specifically direct the Commerce Department to deny licenses for those exporting these items to certain countries unless the exporter can submit documentation to the government "to demonstrate by clear and convincing evidence that, if the license is approved, the technology will not be used for human rights abuses or by an entity that has engaged in human rights abuses."

Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.

The U.S., Japan and South Korea last week agreed to boost export control cooperation -- including enforcement -- to prevent technologies with military or dual-use applications from being “illegally exported or stolen abroad.” The commitment was one of several made after Aug. 18 meetings at Camp David -- the first stand-alone summit among the three nation’s leaders -- and “signifies a new era of trilateral cooperation," National Security Adviser Jake Sullivan said.

The Bureau of Industry and Security this week renewed its temporary denial order for a Venezuela-based cargo airline after saying it continues to try to violate U.S. export restrictions and the terms of the TDO. BIS said Empresa de Transporte Aereocargo del Sur, also known as Aerocargo del Sur Transportation or Emtrasur, has demonstrated "continued disregard" for U.S. export controls.

Sen. Marco Rubio, R-Fla, introduced a bill this week that could lead to new export controls on certain U.S. “genetic technology” destined to China. The Stopping Genetic Monitoring by China Act would add various types of “genetic sampling and testing kits, analytical technology, and software” to the Bureau of Industry and Security’s Commerce Control List, including:

The House last week voted 219-210 to pass its version of the FY 2024 National Defense Authorization Act with several trade related provisions and amendments, including one amendment that would prohibit “any form of sanctions relief” for the Taliban “unless explicitly authorized by Congress in subsequent legislation.” Another provision would block the Defense Department from entering into a procurement contract with any person or entity that has “business operations” with the Russian government, while another “exhorts” the Defense Department to “commit resources” to make sure “foreign military sales officers in the Department are fully staffed to support the fulsome review and expedient transfer of defense articles” to Australia and the U.K.

DOJ this week indicted Gal Luft, former co-director of a Maryland think tank, on charges related to “multiple international criminal schemes,” including arms trafficking and violating U.S. sanctions against Iran. The agency said Luft, a dual U.S.-Israeli citizen who worked at the Institute for the Analysis of Global Security, for “years” worked as a Chinese agent to “advance the interests” of the Chinese government, including by acting as a middleman in a range of illegal weapons and oil deals.

Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.

House lawmakers submitted a host of proposed export control- and sanctions-related amendments as part of the FY 2024 National Defense Authorization Act, including measures that could ease defense technology sharing restrictions, harmonize the Entity List with certain U.S. sanctions and investment restrictions and place new export control requirements on items destined to China and Iran. Other amendments could lead to new sanctions on Chinese technology companies and government officials, add the USDA to the Committee on Foreign Investment in the U.S., establish a new sanctions coordination office in the State Department and more.