A Turkish aviation operator was fined for ferrying passengers into and out of Russia on a US manufactured Gulfstream executive jet without the requisite export license.   The Commerce Department (BIS)  imposed a civil penalty of $285,000 against Sapphire Havacilik San Ltd. STI (Sapphire), an aviation company headquartered in Ankara, Türkiye, to resolve violations of the Export Control Reform Act of 2018 (ECRA). Although the Russian national passengers provided payment to Sapphire through third-party non-Russian charter brokers, such flights into Russia—which were arranged for the benefit of the Russian national or nationals on board—were nevertheless controlled by or under charter or lease by a Russian national.  As such, the relevant flights did not fall within license exception Aircraft, Vessels, and Spacecraft (AVS) and violated Section 764.2(a) of the ECRA.

Treasury’s Office of Foreign Assets Control (OFAC) sanctioned members of one of Guyana’s wealthiest families, Nazar Mohamed and his son, Azruddin Mohamed, their company, Mohamed’s Enterprise, and a Guyanese government official, Mae Thomas , for their roles in public corruption in Guyana. Azruddin and Mohamed’s Enterprise evaded Guyana’s tax on gold exports and defrauded the Guyanese government of tax revenues by under­declaring their gold exports to Guyanese authorities. Between 2019 and 2023, Mohamed’s Enterprise omitted more than 10 thousand kilograms of gold from import and export declarations and avoided paying more than $50 million in duty taxes to the Government of Guyana.

Two men have been indicted and 17 snow machines seized as law enforcement broke up a scheme to ship the equipment to Russia by way of Hong Kong.   Sergey Nefedov, 40, of Anchorage, Alaska, and Mark Shumovich, 35, of Bellevue, Washington, were arrested June 11.  Both are Russian nationals and naturalized US Citizens. According to the indictment, Nefedov and Shumovich told freight forwarders that the snowmachines would be going to Hong Kong, where they knew that a license was not required for export, thereby causing a freight forwarder to provide false information to U.S. authorities by concealing the end user and destination of the snowmachines.

Two Texas men, both of whom were convicted at trial, were sentenced today to 45 months in prison for attempting to violate the International Emergency Economic Powers Act (IEEPA), conspiracy to violate IEEPA and conspiracy to commit money laundering based on their attempt to transact in sanctioned petroleum and launder the proceeds. The conspirators planned to start their scheme with a 500,000-barrel shipment of Iranian oil, but intended to increase the shipments to one or two million barrels per month for a year or more.

U.S. Customs & Border Protection (CBP) published an updated Trade Fact Sheet providing a snapshot of the scope and volume of the bureau's activities. Duties and taxes collected in FY 2023, were $92 billion, down more than 17 percent from the prior year.

A renewed urgency has gripped Capitol Hill's China hawks to call for the Chief of the U.S. Patent & Trademark Office (PTO) to report on patents issued to Chinese inventors.    In place since the Carter Administration and renewed every five years, the United States - China Science and Technology Agreement (STA) "is a vector to give the PRC access to U.S. dual-use research and presents a clear national security risk...The Biden Administration must stop fueling our own destruction and allow the STA to expire," the lawmakers write.

Central Washington Republican Dan Newhouse (R-WA) continues his efforts to limit Chinese land purchases, introducing the ‘No American Land for Communist China Act’’. This bill would prohibit any agent of the government of the PRC, or any business with respect to which the Gov- ernment of the PRC owns 25 percent or more of the equity interests of the business, from purchasing land adjacent to federal land in the U.S, including Indian Country.

To support the Department's announcement of over 300 new sanctions Wednesday, Treasury's Office of Foreign Assets Control (OFAC) is publishing Determinations, General Licenses and FAQs relating to trade with Russia and Belarus

In coordination with the Departments of Treasury and State, the Commerce Department’s Bureau of Industry and Security (BIS) is announcing several significant additional export control restrictions and related actions against Russia.. Among the actions is the issuance of a final rule imposing additional export control measures against Russia and Belarus by expanding the scope of items identified under two EAR supplements that are subject to the EAR’s Russian and Belarusian industry sector sanctions; imposing a “software” license requirement for certain EAR99-designated “software” when destined to or within Russia or Belarus; and narrowing the scope of commodities and software that may be authorized for export, reexport, or transfer (in- country) to or within Russia or Belarus under License Exception Consumer Communications Devices (CCD).

The Treasury and State Departments are  issuing sweeping new measures guided by G7 commitments to intensify the pressure on Russia for its continued war against Ukraine. Wednesday's actions ratchet up the risk of secondary sanctions for foreign financial institutions that deal with Russia’s war economy; restrict the ability of Russian military-industrial base to take advantage of certain U.S. software and information technology (IT) services; and, together with the Department of State, target more than 300 individuals and entities.

Senate Finance Committee Chair Ron Wyden, D-Ore., called on BMW to provide straight answers about its use of parts made by a banned Chinese supplier, following shifting explanations from the German automaker in response to a Finance Committee Democratic staff investigation. “The Committee is continuing to investigate several aspects of BMW’s exposure to forced labor through JWD, its tier 3 supplier,” the Senator wrote in a letter to the automaker.

Canadian helmet manufacturer Galvion, Ltd. has agreed to pay $2,495,000 to resolve allegations that it violated the False Claims Act through the knowing sale of non-conforming parts to the United States Department of Defense. Through prime vendors, the company sold products to the United States under a Defense Logistics Agency program which requires that textiles be sourced from the United States in accordance with the Berry Amendment. The investigation stemmed from a complaint made to the DLA Hotline related to the origin of materials used in the company’s products.

A dual U.S.-Russian citizen pleaded guilty Friday to conspiracy to violate the Export Control Reform Act by exporting firearm parts, components, and ammunition to Russia without the required authorization. Dimitry Timashev, 58, coordinated with an associate in Russia to send weapon parts from the United States to Russia. In exchange, the associate paid tuition for Timashev’s daughter and rent for an apartment in Ekaterinburg, Russia.

At the IPEF Clean Economy Investor Forum participants "identified $23 billion of priority infrastructure projects for consideration"  at the inaugural meeting in Singapore June 6. Among the major committments announced were cloud computing, data center and submarine cable projects, India's first battery energy storage system, a carbon capture scheme in Singapore, and several hundred million dollars of U.S. International Development Finance Corporation (DFC) funding to investment funds in the region.

Congressional Republican China hawks have called for a comprehensive ban on trade and investment dealings with two leading manufacturers of electric vehicle battery systems, Led by the new Chair of the House Select China Committee John Moolenaar (R-MI), the lawmakers wrote letters detailing "shocking new evidence implicating major Chinese battery manufacturers, Gotion and CATL, in Chinese Communist Party state-sponsored slave labor and the ongoing Uyghur genocide." The letters to Mr. Silvers detail supply relationships between the two firms and mineral, metals and labor providers currently under US sanction for their involvement in modern slavery in the Xinjiang Uyghur Region of Western China.

A federal grand jury charged a New York man in a three-count indictment alleging he illegally shipped eastern box turtles and three-toed box turtles, both protected wildlife species, from the United States to China for the global pet trade black market.

Tim O’Toole of Miller & Chevalier sat down with Erich Ferrari of Ferrari & Associates  to discuss demystifying the OFAC delisting process, and avoiding thst sanction in the first place.

Treasury’s Office of Foreign Assets Control (OFAC) is materially amending the Syrian Sanctions Regulations, 31 C.F.R. Part 542. In addition to new prohibitions, OFAC is adding several relevant definitions and interpretations and one new general license.  OFAC is also incorporating, with amendments, one general license; updating six general licenses; and publishing a list of areas in which activities are authorized under General License 22.

The Five Eyes Security Alliance issued a joint bulletin warning about continued efforts by the People’s Republic of China (PRC) to recruit current and former Western military personnel to train the PRC military. "The most sought-after targets to-date have been military pilots, flight engineers, and air operations center personnel. The PRC has also targeted technical experts with insight into Western military tactics, techniques, and procedures," according to the bulletin.

 This report documents defense articles and defense services licensed for permanent export to each foreign country and international organization during fiscal year 2023.

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