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Treasury Sanctions Hundreds in Anniversary package

Sanctioned entities include Mir Payment Systems
Joining British and European allies, the US imposed a further raft of sanctions on Russia and her enablers. Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning almost 300 individuals and entities. This is the largest number of sanctions imposed since Russia’s 2022 invasion of Ukraine. State is designating three Government of Russia officials in connection with Aleksey Navalny’s death; together, Treasury and State are sanctioning over 500 targets. The Department of Commerce is also adding more than 90 companies to the Entity List.
PRC-manufactured ship-to-shore cranes account for nearly 80 percent of cranes at U.S. ports.
White House Tackles Port Security
The White house announced initiatives to improve the cyber security of the US Port infrastructire, with enhanced authorities for the Coast Guard to inspect vessels and write minimum cybersecurity rules.   Additionally, the administration will invest over $20 billion to subsidize the manufacture of cranes in the US and Korea, to reduce a dependance on Chinese supply. There are no plans to replace the over 200 Chinese cranes already in place.
Jig Grinder
Seized Machine Tool Funds to Ukraine Reconstruction
Nearly $500,000 of forfeited proceeds of an illicit machine tool sale to Russian buyers will be used to support a drone-based program to assess the damage Russian aggression has done to Ukraine’s electrical distribution and transmission infrastructure. Deputy Attorney General Lisa Monaco and Estonian Secretary General Tõnis Saar announced  the transfer at the Munich Security Conference Saturday Feb 17.
Detained vehicles include Bentley, Audi & Porsche
Volkswagen Uyghur Customs Jam
Volkswagen said Tuesday that  U.S. Customs had detained several thousand Bentley, Porsche and Audi vehicles at ports because the cars contained a part made by a Chinese supplier on a sanctions list for using forced labor in Xinjiang. The automaker describes the part's origin as a "sub-supplier," meaning a supplier to one of its suppliers—an entity far down the supply chain. Last year VW committed to conducting a supply chain audit for exposure to modern slavery.

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February 2024 Export Practitioner

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Entity List Adds: Web-Monitoring in Egypt; Tech for Chinese Universities

The Commerce Department’s Bureau of Industry and Security (BIS) added two entities to the Entity List under seven entries for activities contrary to U.S. national security and foreign policy interests monday. One entity was found to have been involved in supporting online censorship and surveillance to target political actors and human rights activities in Egypt, and the other is being added for diversion of U.S. items to a Chinese Entity Listed party. 

FATF Plenary Wrap: Trusts, Wires & Russia.

Fhe Financial Action Task Force (FATF), the global standard-setting body for anti-money laundering and countering the financing of terrorism (AML/CFT), concluded its fifth Plenary under the Singaporean presidency on Friday. The FATF made several key advances, including kicking off a public consultation on potential changes to the FATF Recommendation on wire transfer information and the adoption of new guidance on trusts. The FATF also noted its concern on Russian Federation’s growing financial connectivity with North Korea and Iran.

S.Korea, US, Japan Call for Stern Response to DPRK-Russia Arms Trade

The foreign ministers of South Korea, the United States and Japan agreed on the need for a firm response to North Korea's provision of arms to Russia for its war against Ukraine, as well as on enhancing cooperation to address North Korean threats, South Korea's Foreign Ministry said Friday.

$1.5 Billion for Abu Dhabi Owned Chip Plant

The U.S. Department of Commerce and GlobalFoundries (GF) have signed a non-binding preliminary memorandum of terms (PMT) to provide approximately $1.5 billion in direct funding under the CHIPS and Science Act. The proposed funding would support a new state-of-the-art facility, significant capacity expansion, and the modernization of GF’s U.S. manufacturing sites in New York and Vermont, which produce essential automotive, communications, and defense semiconductor technologies.  

Yakuza Leader Nabbed Trading Yellowcake

A member of the Yakuza crime syndicate was indicted Feb. 21 for trafficking nuclear materials, including weapons-grade plutonium, from Burma.  The scheme was uncovered during a DEA investigation into narcotics and firearms trafficking. The Justice Department announced the issuance of a Superseding Indictment charging TAKESHI EBISAWA with conspiring with a network of associates to traffic nuclear materials from Burma to other countries.  

OFAC Sanctions Russian Shipowning Group

Treasury’s Office of Foreign Assets Control (OFAC) has targeted Joint Stock Company Sovcomflot, Russia’s state-owned shipping company and fleet operator. In addition to designating Sovcomflot, OFAC is identifying 14 crude oil tankers as property in which Sovcomflot has an interest.
Enforcement
The Justice Department unsealed of an Indictment charging sanctioned Russian oligarch and the President and Chairman of a Russian state-owned VTB bank, Andrey Kostin, with participating in two separate schemes that violated U.S. sanctions. The first scheme was to operate, maintain, and improve  two superyachts, collectively worth over $135 million, while the second scheme was related to the operation and transfer of Mr. Kostin's home in Aspen, Colorado.
Marking the one-year anniversary of the Disruptive Technology Strike Force, the Departments of Justice and Commerce released a joint fact sheet touting their accomplishments. The Task force initiated 14 cases involving alleged sanctions and export control violations, smuggling conspiracies, and other offenses related to the unlawful transfer of sensitive information, goods, and military-grade technology to Russia, China, or Iran. These cases were brought through the work of U.S. Attorneys’ Offices throughout the country and the Counterintelligence and Export Control Section in Justice Department’s National Security Division.
February 15, the DOJ unsealed charges against Mauricio Gomez Baez, former Senior Vice President of Stericycle LATAM Between 2011 and 2016, Mr. Gomez Baez, a Mexican citizen and resident of Miami conspired with other Stericycle employees and agents to pay approximately $10.5 million in bribes to Mexican, Brazilian, and Argentinian government officials in order to obtain government contracts for medical waste collection for Stericycle.
Sanctions
Oil tanker, port of Murmansk, Russia.

Treasury: Oil Price Cap Phase Two Effective

The Oil Price Cap permits service providers in Coalition countries to support the Russian oil trade only if the oil was sold at or below a specific cap. A Treasury policy note looks at the difference that the price cap is continuing to make three months into the second phase, as the coalition continues to take action to enforce the prohibition against the use of G7 services outside the cap.

EU: 13th Sanctions package tags China and India

The European Union announced another round of sanctions on Russia and her allies, extending the reach to include Chinese and Indian firms complicit in avoiding existing restrictions.  The new measures focus on the procurement network supporting Russia's military, especially the supply chain to make drones. Twenty-seven companies were added to the Annex IV list, which means European firms cannot sell dual-use goods to them.

US& European Sanctions Coordinators Forum in Brussels

Representatives of the U.S. Departments of State, Commerce, and Treasury, along with delegations from the UK and Ukraine, joined senior EU and member state government officials for a Sanctions Coordinators Forum in Brussels Tuesday. "We reaffirmed our shared commitment to supporting Ukraine’s sovereignty and opposing Russia’s aggression and that sanctions are a key tool in that effort. The delegations discussed the use of targeted sanctions to deter and disrupt malign Russian activity and to demonstrate our readiness to take action to defend international norms," according to a State Department readout. The EU Statement was more comprehensive:
Policy Briefs
The Financial Crimes Enforcement Network (FinCEN) published a small entity compliance guide today that provides an overview of the requirements regarding access to beneficial ownership information (BOI) by small entities. The guide includes sections summarizing the Access Rule’s requirements that pertain to small financial institutions’ access to BOI. 
Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson will travel to European capitals this week to coordinate the allied response to the Russian invasion of Ukraine. Nelson's schedule includes the Munich Security Conference, meetings in Brussels with EU counterparts, and in Paris the Plenary of the Financial Action Task Force.
Mayorkas delivered the keynote address to the Munich Cyber Security Conference. "The world is on the cusp of a new era in the digital revolution," he said. "We must answer the question of how security and governance should be exercised on this modern digital landscape, in service of the world’s economic and social well-being."
Supply Chain
Customs & Border Protection has released a new training video "How to Submit Allegations of Forced Labor," the latest in its CBP Trade Webinars series. This video outlines how to submit an allegation for forced labor, including where to submit and what to include in the allegation.
A Florida couple were both sentenced to 57 months in prison for illegally importing and selling between $25 million and $65 million worth of plywood products in violation of the Lacey Act and customs laws.  The defendants engaged in a sophisticated scheme to evade antidumping and countervailing duties owed on hardwood plywood products made in China by falsely declaring the species, country of origin or country of harvest of the wood from which the plywood was made.
French oilfield services giant SLB has applied for the Export Import Bank to extend a long-term loan guarantee in excess of $100 million to entities controlled by the investment arm of the in the Kingdom of Bahrain. The vote for this project comes after resignations from climate advisors who were shut out of project evaluations and deliberations. ExIm also failed to disclose the project funding amount, despite pressure from civil society and environmental groups.
Licensing
Deputy Attorney General Lisa O. Monaco delivered remarks on "the Promise and Peril of AI," at Oxford University February 14, calling  an "inflection point with AI," Claiming that "AI is the ultimate disruptive technology," she vowed that the Distruptive Technology Strike Force established last year to coordinate export control activities, will place AI at the "very top" of its enforcement priority list.
A Montreal woman pleaded guilty to money laundering conspiracy for her role in a multimillion-dollar scheme to send components used in unnamed aerial vehicles (UAVs) and guided missile systems and other weapons to sanctioned entities in Russia.  Last October, a criminal complaint was unsealed, and a Brooklyn, New York, resident and two Canadian nationals were arrested in connection with a global procurement scheme in which the defendants used two corporate entities registered in Brooklyn to unlawfully source and purchase dual-use electronics on behalf of end-users in Russia, including companies affiliated with the Russian military.
A 747 Boeing Freighter was flown to Miami from Buenos Aires by U.S. Marshalls in the latest chapter of the Mahan Air Saga.  Mahan, a sanctioned Iranian airline is affiliated with the Islamic Revolutionary Guard Corp-Qods Force (IRGC-QF), a designated Foreign Terrorist Organization (FTO). On Oct. 20, 2022, in support of its ongoing criminal investigation, the United States filed a civil forfeiture complaint alleging that the aircraft’s transfer from Mahan Air to Empresa de Transporte Aéreocargo del Sur, S.A. (EMTRASUR), a Venezuelan cargo airline and subsidiary of a Venezuelan state-owned company, violated U.S. export control laws.
In two separate cases out of U.S. Attorneys’ Offices on opposite coasts, several individuals are charged – one of whom was arrested yesterday – in connection with sophisticated schemes to transfer sensitive technology, goods, and information for the benefit of hostile foreign adversaries, in violation of U.S. law. In the Eastern District of New York, a fugitive father and son team of Iranian nationals are charged with conspiring to export equipment used in the aerospace industry to the Government of Iran, in violation of the International Emergency Economic Powers Act (IEEPA), in connection with an alleged conspiracy to illegally export U.S. goods and technology without the required licenses. In the Central District of California, a naturalized chinese was arrested for allegedly stealing trade secrets developed for use by the U.S. government to detect nuclear missile launches and track ballistic and hypersonic missiles.
Commerce Secretary Gina Raimondo has announced the creation of the U.S. AI Safety Institute Consortium (AISIC), which will unite AI creators and users, academics, government and industry researchers, and civil society organizations in support of the development and deployment of safe and trustworthy artificial intelligence (AI). The consortium will be housed under the U.S. AI Safety Institute (USAISI) and will contribute to priority actions outlined in President Biden’s Executive Order, including developing guidelines for red-teaming, capability evaluations, risk management, safety and security, and watermarking synthetic content.