The Treasury's Office of Foreign Assets Control’s recent publication of a sanctions compliance guide is the latest example of OFAC’s long-term effort to show companies what makes an effective compliance program, trade lawyers said. But the effort may also ultimately benefit the Treasury, according to one lawyer, by making it easier for the department to successfully prosecute compliance cases.
The Treasury’s Office of Foreign Assets Control reached a settlement of about $870,000 with a New York-based shipbroking company that OFAC said violated weapons-related sanctions five times. The company, MID-SHIP Group LLC, violated the Weapons of Mass Destruction Proliferators Sanctions Regulations by negotiating contracts among ship owners and charterers worth about $470,000 between February and November 2011, OFAC said May 2. The ships used in the transfers were owned by the Islamic Republic of Iran Shipping Lines (IRISL), which was sanctioned by OFAC in 2008.
The Treasury’s Office of Foreign Assets Control published a 12-page guide on sanctions compliance for U.S. and foreign businesses, detailing what OFAC defines as effective compliance programs and outlining several “root causes” of sanctions violations. The guide, published May 2, delves into the level of compliance that OFAC expects from companies and how best to avoid sanctions violations. The guide covers five categories: management commitment, risk assessment, internal controls, testing and auditing, and training.
The Department of the Treasury is “initiating a renewal of the public certificate securing the www.treasury.gov website,” which includes the Office of Foreign Assets Control’s “sanctions list downloads,” OFAC said in a May 1 technical notice. The certificate is being replaced May 16 at 9 p.m. EDT and will take about three to six hours for the "replacement certificate to be distributed worldwide,” the notice said. “If your application pins or otherwise trusts the serial number of the existing certificate as part your application functionality, you may need to update your configuration to trust the renewed certificate,” OFAC said. Questions should be directed to O_F_A_C@treasury.gov or the tech support hotline at 1-800-540-6322.
Reps. Eliot Engel, D-N.Y., and Michael McCaul, R-Texas, are working on legislation that would strengthen U.S.-imposed sanctions on Russia, they said during a House Foreign Affairs Committee meeting May 1. Engel said they are planning to introduce a bill that will “protect America’s interests, ramp up the targeted sanctions, enhance diplomacy and counter propaganda efforts to meet the Russian threat.” McCaul said he and Engel had breakfast with Secretary of State Mike Pompeo earlier that day and said “there’s no doubt” Pompeo “looks at Russia as a great threat” to the U.S. “I don't think this is a partisan issue,” McCaul said. “I hope we can pass legislation out of this committee.”
Export Compliance Daily is providing readers with some of the top stories for April 22-26 in case they were missed.
It's unclear how North Korean leader Kim Jong Un got the armored Mercedes-Maybach limousines made by Daimler that Kim used for several recent meetings with international leaders, a spokesman for the company said. In an April 29 email, a Daimler spokesman said the company has a “comprehensive export control process” to “prevent” all sales to North Korea. “We have no indication how those vehicles have come to the use of” North Korea, he said. Exports of luxury goods to North Korea are banned under United Nations sanctions, and sanctions imposed by the U.S. allow the Treasury’s Office of Foreign Assets Control to designate any person who “engages in a significant export to or import from North Korea,” according to the Treasury.
The Treasury’s Office of Foreign Assets Control sanctioned two Venezuelan officials who it called “corrupt [Nicolas] Maduro insiders,” according to an April 26 press release. OFAC added Jorge Alberto Arreaza Montserrat, Venezuela’s minister of Foreign Affairs, and Carol Bealexis Padilla de Arretureta, a Venezuelan court judge, to the Specially Designated Nationals List.
The Treasury's Office of Foreign Assets Control is issuing regulations for sanctions surrounding foreign interference in U.S. elections, according to an April 26 notice. The regulations require the director of national intelligence to investigate any information that points to the possibility of foreign interference within 45 days after the conclusion of U.S. elections and recommend “remedial actions” for the U.S. government to take, other than sanctions. The regulations also list provisions for sanctioning those involved in election interference, including blocking any U.S.-related “property and interest.”
The Treasury’s Office of Foreign Assets Control announced a settlement of $75,375 with Haverly Systems, a New Jersey software company with offices in Texas and California, for violations of the Ukraine Related Sanctions regulations, OFAC said in an April 25 enforcement notice. Haverly violated the sanctions twice between May 2016 and January 2017 when it “dealt in new debt of greater than 90 days maturity” with JSC Rosneft, a Russian oil company that was designated under Ukraine-related sanctions, OFAC said.