The Treasury’s Office of Foreign Assets Control announced a settlement of $75,375 with Haverly Systems, a New Jersey software company with offices in Texas and California, for violations of the Ukraine Related Sanctions regulations, OFAC said in an April 25 enforcement notice. Haverly violated the sanctions twice between May 2016 and January 2017 when it “dealt in new debt of greater than 90 days maturity” with JSC Rosneft, a Russian oil company that was designated under Ukraine-related sanctions, OFAC said.
Russia is putting in place additional sanctions against Ukraine, including new bans on imports and exports between the two countries, according to a blog post from Baker McKenzie. Effective April 18, Russia is adding to the list of goods that cannot be imported into Russia from the Ukraine tariff headings and subheadings covering paper products, apparel and footwear, metal products and machinery, among other things, according to an unofficial translation of the Russian government’s notice. Russia is also immediately adding tariff provisions covering certain oil and petroleum products and chemicals to the list of goods prohibited for export to the Ukraine. Effective June 1, Russia also is adding goods to a list of products that cannot be exported from Russia to Ukraine without a permit, including coal and more petroleum products.
Venezuelan President Nicolas Maduro is evading U.S.-imposed sanctions by funneling cash from Venezuelan oil sales through a Russian state energy company, according to an April 18 report from Reuters. The cash flowing through Rosneft is the most recent sign of “the growing dependence of Venezuela’s cash-strapped government on Russia” as a result of U.S. sanctions, according to the report.
Even with an already high volume of U.S.-imposed sanctions on Venezuela’s oil and economic sectors within the first few months of 2019, the sanctions are only likely to increase, said Johann Strauss, an international trade lawyer at Akin Gump.
In the April 10 edition of the Official Journal of the European Union the following trade-related notices were posted:
The Treasury’s Office of Terrorism and Financial Intelligence is requesting a nearly $25 million budget increase from the previous year, partly to help with staffing concerns, according to Treasury’s annual budget report. OTFI lists its “increasing role” in the Trump administration as justification for the increased budget. The agency is requesting about $165 million.
The Trump administration is considering increasing sanctions pressure on Venezuela by imposing sanctions on companies from third countries that do business with President Nicolas Maduro and the Venezuelan regime, according to a March 29 report by Reuters. The potential move was announced by John Bolton, White House national security adviser, who told Reuters the administration is moving in the “direction” of secondary sanctions.
A task force of sanctions policy experts published a list of trends that could have an impact on the future of U.S. sanctions, providing evidence of a U.S. shift toward unilateral foreign policy decisions and warning of unintended consequences from sanctions that are increasingly complex, according to a report commissioned by the Center for a New American Security.
Export Compliance Daily is providing readers with some of the top stories for March 18-22 in case they were missed.
The Treasury’s Office of Foreign Assets Control’s recent action of sanctioning Evrofinance -- a Russian bank the U.S. suspects of working with the Venezuelan government -- was a two-part warning to Venezuela, the Kremlin and others, trade lawyer and former OFAC senior sanctions policy adviser Michael Dobson said in an interview. The U.S. will not hesitate to tighten restrictions on Venezuela, Dobson said, and it does not feel constrained to sanction “outside actors” assisting the Nicolas Maduro regime. The sanction (see 1903110014), announced in a March 11 OFAC notice, will be published in the March 22 Federal Register. Dobson, now a lawyer at Morrison Foerster, said he suspects Evrofinance of being a “very narrow vehicle” set up by Russia and Venezuela to facilitate trade and to “release some of the pressure from the Maduro regime's decreasing access to U.S. dollars.” The action will likely not become a trend for Venezuela, Dobson said, but a stand-alone action wherein the U.S. was able to enforce evasions of sanctions. “I think it’s just a warning,” Dobson said, adding that as long as U.S. companies aren’t doing business with Venezuela or Evrofinance, “I don't think this is going to have significant ripple effects.”