The U.S. announced a range of new sanctions and restrictions against Iran, including an executive order, additions to the Commerce Department’s Entity List (see 2009210018) and new sanctions by the Treasury and State Department. The executive order, issued Sept. 21, targets Iran-related arms transfers, while the Treasury and State Department’s sanctions target a range of people and entities associated with Iranian nuclear and arms development.
OFAC
The Treasury Department's Office of Foreign Assets Control (OFAC) administers and enforces various economic and trade sanctions programs. It sanctions people and entities by adding them to the Specially Designated Nationals List, and it maintains several other restricted party lists, including the Non-SDN Chinese Military-Industrial Complex Companies List, which includes entities subject to certain investment restrictions.
The Office of Foreign Assets Control fined a New York telecommunications company and its subsidiary nearly $900,000 for exporting goods and providing services to a sanctioned government entity in Sudan. The company, Comtech Telecommunications Corp., exported warrantied satellite equipment and provided services and training to the Sudan Civil Aviation Authority (SCAA), OFAC said in a Sept. 17 notice. Along with the fine, Comtech said in a settlement agreement it will bolster its sanctions compliance program, including more frequent risk assessments, stricter internal controls and improved employee compliance training.
The U.S. sanctioned more than 45 Iranian people and companies for cyberattacks, and designated two Lebanese companies and a Lebanese official for involvement with Hezbollah. The Iranian sanctions target Advanced Persistent Threat 39 and Rana Intelligence Computing Co. as Ministry of Intelligence and Security-owned or -controlled, the Office of Foreign Assets Control said Sept. 17. Rana was involved in a “years-long malware campaign” that targeted Iranian dissidents, journalists and international companies, OFAC said. The Lebanese designations target Lebanon-based Arch Consulting and Meamar Construction, and Sultan Khalifah As’ad, a Hezbollah Executive Council official “closely associated” with both companies, OFAC said.
The Office of Foreign Assets Control on Sept. 10 designated a member of the Ukrainian parliament and three employees of the sanctioned Internet Research Agency for helping Russia interfere in U.S. elections. The sanctions target Andrii Derkach, a parliament member said to be a Russian agent who helped create “false and unsubstantiated narratives” about U.S. officials ahead of the 2020 presidential election, OFAC said. The agency also sanctioned IRA employees and Russian nationals Artem Lifshits, Anton Andreyev and Darya Aslanova, who helped support IRA cryptocurrency accounts.
The Treasury's Office of Foreign Assets Control sanctioned two United Arab Emirates-based companies and a business owner for supporting sanctioned Iranian airline Mahan Air, an Aug. 19 news release said. The designations target Parthia Cargo, Delta Parts Supply FZC and Iranian national Amin Mahdavi, who owns Parthia Cargo. OFAC said the companies provided “key parts and logistics services” that help Mahan Air sustain its fleet of “western manufactured aircraft.” The parts and services also help the airline transport terrorists, “lethal cargo” and technical equipment to Syria and Venezuela.
The Department of Justice’s recent changes to its voluntary disclosure policies (see 1912130047) could lead to complications for companies and were met with backlash from other enforcement agencies, said Robert Clifton Burns, an export control lawyer with Crowell & Moring. The guidance, which outlined benefits for companies that disclose export control and sanctions penalties, can be interpreted as saying industry should first submit their voluntary disclosures to the Justice Department instead of to other agencies, Burns said.
A U.S. technology company is being investigated by the Office of Foreign Assets Control for possible Iran sanctions violations, the company said in an Aug. 4 Securities and Exchange Commission filing. California-based Harmonic Inc. said OFAC is looking into transactions made with Iran by France-based Thomson Video Networks, which Harmonic acquired in 2016. The company said it may be subject to civil, criminal and monetary penalties, the loss of export privileges or “in extreme cases, imprisonment of responsible employees.”
The U.S. on July 31 sanctioned a Chinese state-controlled organization and two Chinese officials for human rights violations in Xinjiang. The sanctions target the Xinjiang Production and Construction Corps, former XPCC Party Secretary Sun Jinlong and XPCC Deputy Party Secretary Peng Jiarui.
The Treasury and State departments on July 29 sanctioned four people and 10 entities for contributing to the conflict in Syria and for supporting the Syria regime through the construction of luxury real estate. The Treasury’s Office of Foreign Assets Control sanctioned a Syrian businessman and nine entities, while State designated four people and one entity.
The Office of Foreign Assets Control fined Amazon more than $130,000 for violating several U.S. sanctions programs and failing to follow reporting requirements for hundreds of transactions. Amazon processed online orders sent to a range of sanctioned countries in the Middle East and Asia and did not follow the agency’s reporting requirements for more than 300 transactions conducted under a Crimea general license, OFAC said in a July 8 notice. OFAC said the violations were caused by “deficiencies” in Amazon's sanctions screening program.