The Office of Foreign Assets Control last week sanctioned three companies and three vessels for violating the Group of 7 price cap on Russian crude oil. The agency also issued a new general license authorizing certain safety and environmental-related transactions involving those vessels.
End-use certificates can be a good way to mitigate some sanctions and export control risk, but “it doesn't necessarily make the risk completely disappear,” said Jan Dunin-Wasowicz, a Hughes Hubbard trade lawyer. Dunin-Wasowicz cautioned companies about relying solely on end-use and end-user statements when conducting due diligence, adding that companies can take other compliance steps to vet a transaction, especially because some customers are willing to lie about a product's end-use.
The EU General Court on Nov. 29 rejected Russian oligarch German Khan's challenge to his sanctions listing, according to an unofficial translation. The listing criteria had a proper legal basis and were not disproportional, the court said.
The Office of Foreign Assets Control this week sanctioned eight North Korean agents for their work facilitating sanctions evasion – six of them based in third countries – in an action the agency said comes in response to a recent military reconnaissance satellite launch by North Korea. The North Korean agents, including Russia-based Un Hyok Choe and Myong So, China-based Myong Chol Jang and Phyong Guk Kang, and Iran-based Kyong Il Kang and Sung Il Ri, engage in revenue generation and missile-related technology procurement in support of North Korea’s weapons of mass destruction program, OFAC said.
A new bipartisan bill in the Senate and House would allow DOJ to “more quickly” seize sanctioned Russian assets through existing forfeiture processes and transfer proceeds from those assets to help Ukraine’s reconstruction efforts. The Asset Seizure for Ukraine Reconstruction Act, introduced this week, would lift the $500,000 cap on administrative forfeitures of assets owned by Russian oligarchs and others, and would also “clarify DOJ’s transfer authority, ensuring that the U.S. government can transfer to Ukraine all the funds it acquires through seizure of Russian oligarch assets,” according to a news release.
A senior sanctions official with the Treasury Department is in Oman and Turkey this week to discuss sanctions against Hamas and Russia, the agency announced Nov. 27. Brian Nelson, Treasury’s undersecretary for terrorism and financial intelligence, is speaking with the countries about ways they can help prevent Hamas and other terrorist groups from raising and moving funds, facilitate humanitarian aid to the people of Gaza, and prevent and investigate trade that benefits Russia. Nelson’s trip comes after the multiple rounds of U.S. sanctions against Hamas and its financiers since the group’s terror attacks against Israel in October (see 2311140008, 2310270012 and 2310180003).
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The European Parliament last week overwhelmingly adopted three resolutions urging strong EU sanctions against those in Iran, Niger and Georgia involved in human rights abuses. The resolutions call on the bloc to designate the Islamic Revolutionary Guard Corps a terrorist organization and to sanction the country’s supreme leader, president and prosecutor-general. They also said EU member states should implement sanctions against the leaders of a July military coup in Niger, and asked the European Council to sanction those responsible for “violations of Georgian sovereignty” and human rights stemming from Russia's illegal occupation of certain regions of Georgia.
The U.K. last week renewed a Russia-related general license that authorizes certain transactions tied to payments that have been processed by a sanctioned credit or financial institution at some point in the payment chain. The license applies when the sanctioned party acted as an original, correspondent or intermediary institution where the recipient institution and the institution that sent the payment are not designated parties, among other conditions. The license, which was scheduled to expire Dec. 1 (see 2310020016), now lasts through Dec. 14.
The Commerce and Treasury departments earlier this month co-hosted a virtual “exchange” with small to mid-sized financial institutions, law enforcement and government agencies to discuss Russian attempts to evade export controls, the agencies announced Nov. 21. The exchange included officials from the Bureau of Industry and Security, the Office of Foreign Assets Control and the Financial Crimes Enforcement Network, and “exemplified the ongoing U.S. Government effort to further constrain and prevent Russia from accessing the international financial system and conduct economic activity to fund its invasion of Ukraine,” Treasury said. The effort came about a week after BIS and FinCEN issued another set of export control evasion red flags for financial services firms along with a new key term that banks and others can include in their suspicious activity reports (see 2311060055).