Treasury's Office of Foreign Assets Control (OFAC) today announced a $538,000 settlement with Mondo TV, S.p.a. an Italian animation company for 18 apparent violations of the North Korea Sanctions Regulations. Between May 2019 and November 2021, Mondo remitted approximately $537,939 to a Government of North Korea-owned studio in payment for outsourced animation work. In doing so, Mondo caused U.S. financial institutions to process wire transfers that contained the blocked property interests of the Government of North Korea and to export financial services to North Korea.

Deputy Attorney General Lisa Monaco traveled to Brussels last week to lead the U.S. delegation at the U.S.-EU Justice and Home Affairs Ministerial. The Joint Statement from the Ministerial noted that both sides focused on addressing irregular migration, with a view to fight migrant smuggling and trafficking networks, building on the call to action of the Global Alliance to Counter Migrant Smuggling launched in November 2023.

Treasury’s Office of Foreign Assets Control (OFAC) Tuesday sanctioned nearly 50 entities and individuals that constitute multiple branches of a sprawling “shadow banking” network used by Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and Islamic Revolutionary Guard Corps (IRGC) The entities, including cover companies based in Hong Kong, the United Arab Emirates (UAE), and the Marshall Islands have been used to gain illicit access to the international financial system and process the equivalent of billions of dollars since 2020.

The European Council adopted Monday a 14th package of economic and individual restrictive measures on Russia. The package includes restrictive measures on additional 116 individuals and entities , as well as sectoral measures on Energy, Third-Country Subsidiaries and other Anti-Circumvention measures, Financial Communications Systems and Defense Industrial Base, Political Activities, Port Access for specific vessels, dual-use and commodity trade controls, as well as legal protections for sanctions compliance and intellectual property.

Unlicensed exports of fruit flies genetically modified to produce a subunit of a controlled toxin drew Indiana University a  penalty from the  Commerce Department.   As part of a settlement agreement, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an order imposing an administrative penalty on Indiana University (IU) related to exports by IU’s Bloomington Drosophila Stock Center (BDSC).  

Treasury’s Office of Foreign Assets Control (OFAC) is designating two individuals and five entities that have facilitated weapons procurement for Ansarallah, commonly referred to as the Houthis. OFAC is also designating one individual and one company, as well as identifying one vessel, that have facilitated the shipment of commodities, the sale of which provides an important funding stream to the Houthis that aids in their weapons procurement.

The United States last year imported 3 billion pounds of UCO, half of which came from China – up from a total of 200 million pounds imported in 2020. A bipartisan group of senators is calling on the Biden Administration to address this surge in imports.

The Treasury Department Friday issued a Notice of Proposed Rulemaking to implement Executive Order 14105 of August 9, 2023, “Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern”. The NPRM builds on the Advance Notice of Proposed Rulemaking issued by Treasury last August and provides the full draft regulations and explanatory discussion regarding the intent of the proposal, and solicits comment from the public

Just in case you're still depending on a Russian vendor for your cybersecurity, the Commerce Department has banned Kaspersky Labs from directly or indirectly providing anti-virus software and cybersecurity products or services in the United States or to U.S. persons. The Final Determination by the Bureau of Industry and Security (BIS) is the first of its kind and is the first Final Determination issued by BIS’s Office of Information and Communications Technology and Services (OICTS).  

The Export-Import Bank of the United States (EXIM)  signed a US$500 million Memorandum of Understanding (MOU) for the Republic of Trinidad and Tobago. in a ceremony in Port of Spain, Trinidad June 20. The MOU will develop opportunities and support financing in the "maritime domain awareness, cybersecurity, renewable energy, and water sanitation sectors."  In addition, the bank delivered a  $150 million Letter of Interest to finance "maritime vessels and aircraft in support of its maritime operations."

Treasury’s Office of Foreign Assets Control (OFAC) is designating a network of two individuals and seven entities that provide major sources of revenue for U.S.-designated Republika Srpska (RS) President Milorad Dodik and his family. Dodik used his official position to direct RS government contracts to a network of private companies that he and Igor oversee. While Igor controls many of the companies in this network, he obfuscates his personal connection to the companies by relying on distinct nominal owners and directors.

The Commerce Department’s Bureau of Industry and Security (BIS) expects to issue a final rule this Summer revising the Export Administration Regulations (EAR) to authorize the release of certain technology and software in the context of standards setting and development in standards organizations. Much of the rulemaking activity was initiated in response to the Huawei sanctions and US firms' continued participation in 5G telecoms standards negotiations.  The Bureau published the interim rule in June of 2020, incorporating comments in a follow on interim rule two years later.

BIS Published the final rule announced last week as part of the Administration's participation in the G7 summit. The bulk of the rule is as displayed last week, though the published version adds additional EAR 99 software to coordinate with allies,

A Canadian national and resident of the People’s Republic of China (PRC), pleaded guilty today to conspiring to send trade secrets that belonged to Tesla Motors. …

The new Iran Foreign Direct Product rules go into effect next month, and the unusual way the rule was imposed may have left some practitioners unprepared.  Enacted by Congress with no input from the Deparetment of Commerce, the provisions of (HR. 6603) introduced by Rep. Nathaniel Moran (R-TX) were included in the massive emergency supplemental appropriation [HR 815] signed into law April 24th.  "This is the first time in the history of Congress that it passed a bill to codify a foreign direct product rule," Mr. Moran's office stated.

The Department of Commerce’s Bureau of Industry and Security (BIS) has imposed a three-year denial order against a Portland, Oregon, package forwarding service prohibiting the firm from from participating in all exports under BIS jurisdiction from the United States. “If a forwarding company – with an entire business model based on exports – fails to implement an adequate compliance program even while subject to a suspended denial order, it should not be able to export items subject to the EAR from the United States,” said Assistant Secretary for Export Enforcement Matthew S. Axelrod.

The House of Representatives passed their version of the FY23 National Defense Authorization Act.  The narrow 217 to 199 vote on the normally nonpartisan legislation reflected the last minute addition of a raft of culture war amendments which alienated all but six Democrats.

Coordinator on Global Anti-Corruption Richard Nephew will travel to Montenegro, Lithuania, and Albania June 16-21. Mr. Nephew will visit Podgorica, Montenegro to meet with government officials and civil society representatives. He will then travel to Vilnius, Lithuania on June 18-19, to the opening plenary of the International Anti-Corruption Conference.

 Congressional China hawks called for the Commerce Department to include Chinese drones in evolving regulations for connected vehicles.  "With UAVs’ connected software and hardware posing similar national security threats to those of other identified connected vehicles, such transactions present undue and unacceptable risks to U.S. national security," the lawmakers wrote.

After Chinese fast fashion powerhouse pulled its plans to list shares in the US, Congressional bedevilment persists. Senator Marco Rubio (R-FL) sent a letter to the U.K. Chancellor of the Exchequer, Jeremy Hunt, informing him of SHEIN’s reported human-rights abuses and exploitation of trade loopholes and the risks these tactics pose to businesses and investors. The letter urges Hunt to investigate SHEIN thoroughly before allowing the company to list on the London Stock Exchange.