A US telecommunications company may have violated U.S. sanctions against Sudan, according to the company’s Dec. 4 filing with the Securities and Exchange Commission. Comtech Telecommunications Corp. disclosed to the Treasury's Office of Foreign Assets Control in 2014 that it sent a “shipment of modems” to a Canadian customer, which was eventually “incorporated into a communication system” destined for an end-user at the Sudan Civil Aviation Authority, the filing said. OFAC subpoenaed Comtech in 2015 for information about the sale, the company said, which was worth about $288,000. Comtech responded to the subpoena and alerted OFAC of the company’s repair of three modems for a Lebanese customer who may have rerouted the modems from Lebanon to Sudan without the required U.S. license, the filing said. Comtech entered into two tolling agreements with OFAC, including one in November, which extends the statute of limitations in the case through June 2020.
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.
An Iranian businessman was sentenced to 46 months in prison for illegally exporting carbon fiber from the U.S. to Iran, the Justice Department said Nov. 14. Behzad Pourghannad worked with two others between 2008 and 2013 to export the carbon fiber to Iran from third countries using falsified documents and front companies, the agency said.
Apple was fined about $465,000 for violations of the Foreign Narcotics Kingpin Sanctions Regulations after it hosted, sold and “facilitated the transfer” of software applications and content belonging to a sanctioned company, the Treasury’s Office of Foreign Assets Control said in a Nov. 25 notice. Apple allegedly dealt in “the property and interests” of SIS d.o.o., a Slovenian software company added to OFAC’s Specially Designated Nationals List in 2015.
A U.S. electronics and computer component company may have violated U.S. sanctions on Iran and Syria, the company said in a Nov. 7 filing with the Securities and Exchange Commission. Colorado-based Arrow Electronics said a “limited number of non-executive employees … facilitated product shipment” to customers for re-export to people covered by U.S. sanctions on Iran and Syria. The transactions took place between 2015 and 2019 and were valued at about $5,000, the company said. Arrow Electronics said it voluntarily disclosed the potential violations to the Treasury’s Office of Foreign Assets Controls and the Commerce Department Bureau of Industry and Security earlier this year. It also disciplined or fired employees involved in the transactions and said it plans to “cooperate fully” with BIS and OFAC. The company said it is not able to “estimate” the potential penalty it may receive.
A Virginia-based information technology company may have violated U.S. sanctions in 2017, the company said in a quarterly filing with the Securities and Exchange Commission for the period ended on Sept. 30. The company, DXC Technology, said it voluntarily disclosed possible violations to the Office of Foreign Assets Control stemming from “insurance premium data and claims data” processed by two partially owned joint ventures of Xchanging, a London technology company that DXC acquired in 2017. DXC also sent a copy of the disclosure to the United Kingdom’s Office of Financial Sanctions Implementation. The company said it is “finalizing its internal investigation” of the violations and plans to give OFAC more information in early 2020.
U.S. sanctions on two large shipping companies last month disrupted the tanker market, forcing oil traders to cancel bookings and causing rates to spike as they searched for other ships, according to a September post from Clyde & Co.
A U.S. manufacturing company disclosed it may have violated U.S. sanctions on Iran, in a filing with the Securities and Exchange Commission. The company, H.B. Fuller, said it voluntarily disclosed the possible violations to the Treasury Department in September 2018 after discovering its subsidiaries in Turkey and India may have sold its products to customers who then resold them to Iran. The possible violations began in Turkey in 2011 and in India in 2014, the company’s Sept. 27 filing said, and involved the resale of “hygiene products.”
The United Kingdom must improve its outreach and guidance to the private sector to make sure its post-Brexit sanctions regime is effective, a task force organized by the Royal United Services Institute said in a September report. The task force, composed of former U.K. sanctions officials, policy experts and private sector representatives, said Britain should review and increase staffing within its sanctions regimes and consider adopting some of the sanctions guidance tools provided by the U.S. Treasury’s Office of Foreign Assets Control, RUSI said.
It may only be a matter of time before countries create a trade payment system to avoid U.S. sanctions, said David Mortlock, a trade lawyer and senior fellow with the Atlantic Council.
President Donald Trump issued an executive order Sept. 10 that “strengthens and expands” the State and Treasury departments' sanctions authorities against terrorists, the Treasury's Office of Foreign Assets Control said in a notice. Among several changes, the order allows the U.S. to impose “correspondent account or payable-through account sanctions” on foreign banks that “knowingly conducted or facilitated any significant transaction” for a U.S. sanctioned global terrorist, OFAC said.