Germany announced the extension of general permits for exports in a March 17 notice, according to an unofficial translation. General Licenses No. 12 to No. 14 and General Licenses No. 16 to No. 28 are extended to March 31, 2022. General License No. 15 was already deemed valid until the same date. The update also detailed information on General License No. 28 -- Franco-German cooperation on export controls in the arms sector derived from the Franco-German Treaty of Aachen of 2019. The agreement gives privileges to de minimis arms exports. Also, in relation to arms exports from Germany to France, registration for the General Approval must be completed before use of the permit, a preliminary procedure must be made in certain cases and the General License user must request a “declaration of integration” from a French regulator. The general license provision entered into force April 1, 2020.
The Bureau of Industry and Security denied export privileges for a German aircraft maintenance company and fined it more than $50,000 for procuring U.S. parts and components for a sanctioned Iranian airline. MSI Aircraft Maintenance Services International GmbH & Co. worked with Iran’s Mahan Airways (see 2011270001) to illegally export U.S.-origin reservoir and valve assemblies, which were controlled under the Export Administration Regulations, BIS said in a March 5 order. The agency said it will waive MSI’s three-year export denial if the company pays the fine, cooperates with BIS during a three-year probationary period and doesn’t commit any more EAR violations.
The U.S. sanctioned a host of Russian officials and agencies, will add 14 entities to the Entity List and will increase restrictions on exports of military-related goods to Russia in response to the poisoning and imprisonment of Russian opposition leader Alexei Navalny. The increased export controls will also remove certain license exceptions for shipments to Russia and will impose stricter license review policies for certain sensitive goods, the State Department said March 2.
Apple last week introduced a new ethics and compliance webpage, featuring a detailed outline of its trade compliance policies surrounding export controls and sanctions. A table of all Apple products provides their respective Export Control Classification Numbers and which destinations are blocked from receiving Apple products. The company said all its products qualify as mass market products and are subject to the Export Administration Regulations but are not controlled as dual-use goods by the Wassenaar Arrangement. Apple said some of its goods may be eligible for the Office of Foreign Assets Control’s Iranian General License No. D1 and Bureau of Industry and Security license exceptions related to Cuba. OFAC fined Apple about $465,000 in November 2019 after the company hosted, sold and helped transfer software applications and content belonging to a sanctioned company (see 1911250064).
An American animal pharmaceutical company may have violated U.S. sanctions after acquiring a company that illegally sold goods to Iran, Zoetis disclosed in a Feb. 16 Securities and Exchange Commission filing. Zoetis said it acquired Platinum Performance in August 2019 and soon discovered that Platinum had sold food, medicine or “devices” to people or entities with ties to Iran, adding that the sales were not approved by a Treasury Department general license. Zoetis submitted an initial voluntary disclosure to the Office of Foreign Assets Control in February 2020 while it conducted an internal investigation, and in December 2020 submitted a final disclosure to both OFAC and the Justice Department. The agencies have said they don't comment on ongoing investigations.
The Office of Foreign Assets Control deleted several designations, revoked five general licenses and removed three frequently asked questions from its website to reflect the State Department’s decision last week to revoke the terrorist designation of Ansarallah (see 2102100016). The changes, which took effect Feb. 16, rescinded several general licenses that authorized humanitarian-related trade and other transactions with Yemen and Ansarallah, the Iran-backed Houthi movement (see 2101250043 and 2101190016). OFAC clarified that U.S. people and companies no longer require OFAC authorization “to engage in transactions or activities with Ansarallah, provided such activities do not involve blocked persons or otherwise prohibited activities.”
In one of its first major decisions to reverse Trump administration-imposed sanctions, the State Department will revoke its terrorism designation of Ansarallah Feb. 16. The move, which reverses the designation of the Yemen-based group also known as Houthis as a Foreign Terrorist Organization, came after the State Department said it was reviewing the humanitarian implications of the designations. The Treasury Department's Office of Foreign Assets Control in January issued several general licenses and frequently asked questions to clarify that the sanctions wouldn't impact humanitarian exports to Yemen, including those sent by international organizations (see 2101190016 and 2101250043), but the State Department said the designation could still hamper some aid delivery.
The Treasury Department isn’t doing enough to limit the impacts of U.S. sanctions on humanitarian aid to Venezuela, the Government Accountability Office said in a report. Although Treasury has taken steps to mitigate the sanctions’ impact -- including through general licenses and by responding to individual questions about humanitarian aid -- GAO said the agency doesn’t “systematically track and analyze information from these inquiries” to spot trends or repeating issues. “Without collection and analysis of this information,” the GAO said Feb. 4, “Treasury and its interagency partners may be limited in their ability to develop further actions to ensure that U.S. sanctions do not disrupt humanitarian assistance.”
The Office of Foreign Assets Control on Feb. 2 updated a general license that authorizes transactions involving Venezuela’s ports and airports. General License No. 30A, which replaces No. 30 (see 1908060048), also authorizes certain transactions and activities that involve Venezuela’s Instituto Nacional de los Espacios Acuáticos (INEA) or any entity INEA owns by 50% or more. OFAC said the license does not authorize transactions or activities related to the export or reexport of “diluents” to Venezuela.
The Office of Foreign Assets Control extended a general license authorizing certain transactions involving securities of companies that “closely” match the name of a company identified as a Chinese military company (see 2011130026), a Jan. 27 notice said. General License No. 1A, which replaced General License No. 1 (see 2101120026), authorizes the transactions through 9:30 a.m. EDT May 27 and past the original expiration date of Jan. 28. OFAC also added language to the license to specify that it does not authorize transactions with securities of entities listed on OFAC’s Non-Specially Designated Nationals Communist Chinese Military Companies List or Defense Department-issued lists (see 2101150006). The agency updated frequently asked questions 878 and 879 to reflect the change.