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Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an update to the March 2019 OFAC Advisory to the Maritime Petroleum Shipping Community to highlight risks associated with shipments to Syria. Amendments to this advisory include updates to certain deceptive shipping practices and risk mitigation measures, along with an updated annex of vessels currently identified as blocked property on OFAC’s SDN List, that have been involved in fuel shipments to Syria.

Majority staff from the Homeland Security and Select China Committees released a report recapping their efforts to draw attention to the role of Chinese suppliers in U.S. Port Security.    China's Shanghai Zhenhua Heavy Industry Co., Ltd. (ZPMC), the world’s largest STS crane manufacturer is an entity of particular focus of the report.   Producing nearly 80% of the STS cranes used at U.S. ports ZPMC commands 70% of the global market share.  

The Commerce Department’s Bureau of Industry and Security (BIS) issued a final rule making changes to the Export Administration Regulations (EAR) related to BIS’s policies and practices regarding voluntary self-disclosures (VSDs) and to the BIS Penalty Guidelines. The rule revises the BIS Penalty Guidelines to change how the Office of Export Enforcement (OEE) calculates the base penalty in administrative cases and how OEE applies various factors to the base penalty to determine the final penalty.

Additionally, OFAC put on public inspection Interim Final Rule to Extend Recordkeeping Requirements from Five to 10 Years, consistent with the extension of the statute of limitations for violations of certain sanctions administered by OFAC. OFAC also put on public inspection a Comment Request for Reporting, Procedures and Penalties Regulations and Other Information Collections Maintained by OFAC for comments concerning OFAC's information requirements.

An India- and New Jersey-based man who operated jewelry companies in New York City’s Diamond District admitted today to spearheading a scheme to illegally evade customs duties for more than $13.5 million of jewelry imports into the United States and with illegally processing more than $10.3 million through an unlicensed money transmitting business, U.S. Attorney Philip R. Sellinger announced.

The Securities and Exchange Commission announced that Deere & Company, which does business as John Deere, agreed to pay nearly $10 million to resolve SEC charges that it violated the Foreign Corrupt Practices Act (FCPA) arising out of bribes paid by its wholly owned subsidiary, Wirtgen Thailand. Thailand employees bribed Thai government officials with the Royal Thai Air Force, the Department of Highways, and the Department of Rural Roads to win multiple government contracts and also bribed employees of a private company to win sales to that company.

An Israeli freight forwarder pleaded guilty to conspiracy to commit export control and smuggling violations for his role in a scheme to illegally ship aircraft parts and avionics from U.S. manufactures and suppliers to Russia, including for the benefit of sanctioned Russian airline companies. As part of his plea agreement, Gal Haimovich, 49, admitted that his scheme involved deceiving U.S. companies about the true destination of the goods at issue, and that the defendant and others attempted to conceal the scheme by submitting false information in export documents filed with the U.S. government. A sentencing hearing has been set for Nov. 22.

The Commerce Department has announced a new tool for analyzing supply chain resiliance.   Introduced at the inaugural Supply Chain Summit in Washington, the SCALE tool represents an effort to build the U.S. Government’s analytical capacity to understand and address supply chain risk. Officails also used the event to announce a redoubled effort to direct federal funds to favored industries via the Chips and Science Act and the Bipartisan Infrastructure Law.

The Georgia Institute of Technology announced it is shuttering its Shenzhen campus and closing a chapter of educational cooperation in the “China’s Silicon Valley” dating back to 1984. To date, Tianjin University remains on the Entity List, making Georgia Tech’s participation with Tianjin University, and subsequently GTSI, no longer tenable" the Iniversity said in a statement.

The US and allies announced a coordinated response to punish the government of Iran for supplying missiles to Moscow for use in Ukraine.  In a significant step, the allies promised sanctions against Iran Air, further crippling the Airbus-dependant state carrier. Existing sanctions have grounded much of the carrier's fleet of Airbus and ATR aircraft, with reports from last summer saying more than two-thirds were out of service.    The average age of the fleet exceeds 25 years.

The U.S. Department of Defense and Indian Ministry of Defence (MoD) participated in the third India-U.S. Defense Acceleration Ecosystem (INDUS-X) Summit in Silicon Valley, California on Monday, …

BIS has recently updated its Guidelines for Preparing Export License Applications Involving Foreign Persons (Deemed Exports/Reexports). Deemed exports are most often encountered in the employment context however, this guidance also addresses license submission requirements related to releases of controlled “technology” and “source code” to foreign persons in other contexts, such as foreign students participating in collaborative research when there are restrictions on publication or foreign students participating in curricular practical training (CPT) or optional practical training (OPT).

On September 6, the U.S. Departments of State, Agriculture, Commerce, Homeland Security, and Treasury jointly released an updated warning for U.S. businesses about risks to their operations and activities in Hong Kong. Risk factors that were formerly limited to mainland China are now also a concern in Hong Kong and could affect commerce, trade, and seemingly routine individual commercial activities in Hong Kong. Many of these risks stem from the 2020 Law of the People’s Republic of China on Safeguarding National Security in the Hong Kong SAR (National Security Law, or NSL), as well as the Safeguarding National Security Ordinance (SNS Ordinance), which was enacted in March 2024 under Article 23 of Hong Kong’s Basic Law.

BIS released a Notice of Proposed Rulemaking outlining a new mandatory reporting requirement for the world’s leading AI developers and cloud providers. The proposed rule requires developers of the most powerful AI models and computing clusters to provide detailed reporting to the federal government. This includes reporting about developmental activities, cybersecurity measures, and outcomes from red-teaming efforts, which involve testing for dangerous capabilities like the ability to assist in cyberattacks or lower the barriers to entry for non-experts to develop chemical, biological, radiological, or nuclear weapons.

A 76-year-old Texas man has been taken into custody on charges of smuggling parts and components used in the production of unmanned aerial vehicles (UAVs), as well as other manned aircraft, from the United States to Iran. The complaint alleges that on several occasions, authorities searched Goodarzi’s luggage and found numerous aircraft parts and components hidden within articles of clothing.

The Justice Department today announced the seizure of a Dassault Falcon 900EX aircraft owned and operated for the benefit of Nicolás Maduro Moros and persons affiliated with him in Venezuela. The aircraft was seized in the Dominican Republic and transferred to the Southern District of Florida at the request of the United States based on violations of U.S. export control and sanctions laws.

The Commerce Department should adopt a blanket “presumption of denial” posture for export license applications that would send critical technology to any entity based in China, according to Sen. Marco Rubio (R-Fla). Commerce should impose the strict controls because of the demonstrably high risk that such applications are intended to circumvent export controls, the senator said.

A new air cargo screening directive issued Aug. 21 by the TSA has some carriers looking for clarification from the U.S. government, and at least one carrier has issued an embargo on U.S. routes via Europe.   The emergency amendment – with restricted access –requires carriers to submit additional details of shippers and consignees to the US Customs and Border Protection agency.

A Virginia  couple were indicted for sanctions violations and money laundering related to the Husband's work as a TV presenter and the wife's acting as an art & collectibles procurement agent for sanctioned Russian oligarch Aleksander Udoddov.

Bureau of Industry and Security (BIS) is implementing export controls on several semiconductor, quantum, and additive manufacturing items with an interim final rule published September 6th.   The rule adds and revises Export Control Classification Numbers (ECCNs) in the Commerce Control List, adds a new license exception for countries that have implemented equivalent technical controls, and adds two new worldwide license requirements to the national security and regional stability controls in the Export Administration Regulations (EAR). The new controls include a limited number of deemed export requirements in the sectors of quantum computers, materials, and related electronic assemblies; aerospace technology; and integrated circuit “development” or “production.”

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