The Treasury’s Office of Foreign Assets Control issued an April 16 guidance clarifying available humanitarian trade exemptions for U.S. sanctions regimes that target Iran, Venezuela, North Korea, Syria, Cuba and Ukraine/Russia. The guidance outlines the specific exemptions available for personal protective equipment and stresses that the U.S. will not target legitimate humanitarian trade to sanctioned countries. The guidance comes amid calls from current and former lawmakers and trade experts for more clarity surrounding OFAC humanitarian waivers (see 2004100044, 2004070028 and 2004010019), which has caused confusion among industry (see 2004140027).
Although the U.S. provides broad exemptions for humanitarian exports to Iran, the exemptions continue to be a source of confusion for industry, which is hindering humanitarian trade with Iran, said Katherine Bauer, a former senior policy adviser for Iran at the Treasury Department. The Treasury’s Office of Foreign Assets Control may issue guidance to clarify the exemptions, Bauer said, but the Trump administration is unlikely to make any major changes to its Iranian sanctions regulations.
The Treasury’s Office of Foreign Assets Control updated a Venezuela-related general license and amended a Venezuela-related frequently asked question, OFAC said in an April 10 notice. General License No. 5C authorizes certain transactions related to Petroleos de Venezuela involving an 8.5% bond on or after July 22, 2020. The FAQ clarifies which transactions are authorized by the license.
After current and former lawmakers asked the Treasury Department to clarify its stance on humanitarian exports to sanctioned countries, the agency pushed back on accusations that sanctions are stopping those exports, saying it does not target legitimate exported aid. Some of those accusations are marred by a misunderstanding of Treasury’s general licenses and exemptions, said sanctions lawyer Doug Jacobson: they do allow a broad range of humanitarian exports to countries like Iran.
The Treasury’s Office of Foreign Assets Control updated the North Korean Sanctions Regulations by adding new sanctions provisions and exemptions and amending the definition for “luxury goods,” according to a notice in the Federal Register. OFAC also made several technical edits to three definitions, revised an “interpretive provision” and updated the “authorities and delegations sections” of the regulations.
The Treasury’s Office of Foreign Assets Control is adjusting its civil monetary penalties for inflation, the agency said in a notice. The notice includes a table detailing the existing and new maximum penalty amounts.
The Treasury Office of Foreign Assets Control’s April 6 sanctions targeted a white supremacist group and its three leaders (see 2004060050), the State Department said April 6, announcing its own designation of the Russian Imperial Movement as a Specially Designated Global Terrorist. The sanctions against RIM marked the “first time the United States has ever designated foreign white supremacist terrorists,” State said. The group provides paramilitary-style training to Neo-Nazis and white supremacist, the agency said.
The U.S. should expand the scope of humanitarian license exceptions for exports to Iran and add staffing within the Treasury Department to speed up the licensing process, members of the European Leadership Network and The Iran Project said April 6. The statement, signed by 25 former U.S. and European government officials, also said the U.S. needs to do more to assure companies, banks and organizations they will not be targeted for exporting humanitarian items to Iran. The letter follows similar calls by U.S. lawmakers, who said sanctions are hindering life-saving exports to Iran (see 2004010019).
The Treasury’s Office of Foreign Assets Control added three Russian nationals and one Russian entity to its Specially Designated Nationals List, OFAC said in an April 6 notice. The sanctions target Denis Valiullovich Gariyev, Nikolay Nikolayevich Trushchalov, Stanislav Anatolyevich Vorobyev and the Russian Imperial Movement. OFAC did not immediately release more information on the designations.
The Federal Aviation Administration does not independently vet civil aircraft registrations, which could lead to a host of sanctions related risks, according to a March report from the Government Accountability Office. In at least one case, the FAA allowed a sanctioned Venezuelan drug trafficker to obtain a dealer certificate, which gave his front company access to blocked planes for more than a year, the GAO said. FAA officials said they do not have the required authorities to address sanctions issues, but the GAO pointed to a lack of coordination between FAA and the Treasury's Office of Foreign Assets Control and a flawed FAA registration system.