The Office of Foreign Assets Control this week designated Iran’s Islamic Revolutionary Guard Corps Cooperative Foundation along with five of its board members, Iran's deputy minister of intelligence and security, and four senior IRGC commanders.
Sharath Patil, former associate attorney at Diaz Trade Law, has joined the Treasury Department's Office of Foreign Assets Control as a sanctions enforcement officer, according to his LinkedIn page. Before working at Diaz Trade Law, Patil was research director for international trade at the nonprofit advocacy group Public Citizen.
The Office of Foreign Assets Control removed one individual, Hanna Khalifeh, across three separate entries from its Specially Designated Nationals List, according to a Jan. 19 announcement. Khalifeh was listed on the SDN List for counterterrorism reasons. OFAC didn't immediately provide more information.
The Office of Foreign Assets Control Jan. 17 again extended a general license that continues to delay an exemption that would authorize certain transactions related to Petroleos de Venezuela, S.A. General License 5J, which replaced GL 5I, now authorizes certain transactions with PdVSA involving an 8.5% bond on or after April 20. The agency also updated a frequently asked question to reflect the change. The previous license was set to allow those transactions to occur on or after Jan. 20.
The Office of Foreign Assets Control this week updated three Russia-related general licenses and four frequently asked questions.
The Office of Foreign Assets Control is adjusting its civil monetary penalties for inflation, the agency said in a notice. The new amounts include higher maximum penalties for violations of the Trading With the Enemy Act, the International Emergency Economic Powers Act, the Antiterrorism and Effective Death Penalty Act, the Foreign Narcotics Kingpin Designation Act and the Clean Diamond Trade Act. The agency also updated two references to “one-half the IEEPA maximum CMP from $165,474 to $178,290” and adjusted the record-keeping CMPs in OFAC’s Economic Sanctions Enforcement Guidelines. The changes take effect Jan. 13.
The Office of Foreign Assets Control this week renewed a general license that authorizes certain transactions related to safety and environmental measures for certain sanctioned vessels. General License 21B, which replaces GL 21A, is valid through 12:01 a.m. April 13. The license was scheduled to expire Jan. 14 (see 2212140028)). OFAC also updated Frequently Asked Question 1097 to reflect the update.
The Office of Foreign Assets Control Dec. 30 fined a multinational Danish-based refrigeration manufacturer more than $4.3 million for violating U.S. sanctions against Iran, Syria and Sudan. Danfoss, which also sells air conditioners and other cooling and heating products, illegally directed customers in all three countries to make payments through a U.S. financial institution, OFAC said in an enforcement notice. The company also made illegal payments to entities in Iran and Syria.
The Office of Foreign Assets Control published guidance this week on a September general license that expanded the types of internet and communications services and exports that can be provided to Iran (see 2209230037). General License D2 made several “key changes” to GL D1, OFAC said in a new frequently asked question, including language to “expand and clarify the range” of U.S. software and services that can be provided to Iranians.
Export Compliance Daily is providing this recap of export control and sanctions enforcement over the past year to assist export compliance professionals, lawyers and others in staying up to date with current enforcement trends. This guide summarizes the most notable enforcement actions by the Commerce Department's Bureau of Industry and Security, the State Department’s Directorate of Defense Trade Controls, the Treasury Department’s Office of Foreign Assets Control and the Department of Justice since Jan. 1, 2022.