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A Russian national based in Hong Kong pleaded guilty to money laundering and smuggling charges for illicitly procuring dual-use, military-grade microelectronics for export to Russia, Members of the conspiracy procured these sensitive microelectronics by falsely representing to the U.S. distributors (who, in turn, are required to report to U.S. agencies) that the Hong Kong shell entity was sending the shipments to end users located in China, Hong Kong, and other countries outside of Russia for use in electron microscopes for medical research. In reality, the OLED micro-displays were destined for end users in Russia.

The Departments of Justice, Commerce, and Treasury’s Office of Foreign Assets Control, have issued a Tri-Seal Compliance Note: Obligations of foreign-based persons to comply with U.S. sanctions and export control laws. The Note highlights the applicability of U.S. sanctions and export control laws to persons and entities located abroad, as well as the enforcement mechanisms that are available for the U.S. government to hold non-U.S. persons accountable for violations of such laws, including criminal prosecution.

Beleaguered Swedish telecoms maker Ericsson has shaken up its compliance operation once again, naming Becky Rohr, current head of investigations, head of compliance as well.  Jan Sprafke, appointed compliance chief six months ago, will be leaving the company.     Ms. Rohr was previously Vice President, Anti-Corruption and Global Trade, Ethics & Compliance Office at Hewlett Packard, and held numerous roles in civil and criminal fraud prosecution in the Justice Department.  She will keep her office in Washington, DC.

As we reported last week, the Financial Action Task Force (FATF), completed its plenary and issued outcomes and updates, including an update of its lists of jurisdictions with strategic AML/CFT/CPF deficiencies This week Financial Crimes Enforcement Network (FinCEN) is informing U.S. financial institutions of the continued suspension of the membership of the Russian Federation. 

The Bureau of Alcohol, Tobacco, Firearms and Explosives, Department of Justice has published two notices for firearms dealers. The first reviews form 9, for approval to export. The second governs reporting of certain long gun sales in southern border states.

The nation"s chief regulator for consumer safety told a congressional panel that the flood of small packages from China has rendered effective enforcement impossible. Consumer Product Safety Commission (CPSC) director of the Office of Import Surveillance James Joholske told the panel that his agency's resources were overwhelmed by fast-fashion and Fulfilled by Amazon third party shipments.

“According to CBP, more than 485 million de minimis shipments have already entered the United States in FY24, on top of the 1.05 billion shipments that entered tax-free under de minimis rules in 2023, itself a shocking 53% increase from 2022," reads a report from Chairman Mike Gallagher (R-WI) of the House Select Committee on the Chinese Communist Party, "No less than 94% of all import transactions now enter the U.S. through De Minimis rules, accounting for 90% of all illegal narcotics, agricultural goods, and counterfeit seizures by customs," said the lawmaker.

The Boeing Company will make three $9 million payments to the government to settle a pattern of material violations of export control law, including unauthorized exports of USML controlled technical data, unauthorized exports of defense articles, and Unauthorized Exports Resulting from Fabricated Permanent Export Licenses. The company agreed to name a Designated Official to head a review of the firms compliance and to spend at least $24 million on consultants, auditors and training.

Beginning on the effective date of March 1, 2024, all entry and certified from summary transactions that include Russian diamonds will require a self-certification statement to be uploaded to the Automated Commercial Environment (ACE) Document Image System (DIS).

Following the lead of its fellow commodity trading firms Vitol, Freepoint, Trafigura and Glencore, Geneva-based Gunvor Group., has pleaded guilty and will pay over $661 million to resolve an investigation by the U.S. Justice Department into violations of the Foreign Corrupt Practices Act (FCPA). Gunvor’s guilty plea stemmed from the company’s corrupt scheme to pay substantial bribes to Ecuadorean government officials to secure business with Ecuador’s state-owned and state-controlled oil company, Petroecuador.

President Biden issued an Executive Order intending to prevent the large scale transfer of Americans’ personal data to “countries of concern,” including Russia and China.  The Executive Order targets personal and sensitive information, including genomic data, biometric data, personal health data, geolocation data, financial data, and certain kinds of personally identifiable information.

A Florida man pleaded guilty Wednesday to federal criminal charges for conspiring to illegally export thousands of turtles to Germany and Hong Kong, and falsifying documents to conceal his conduct. In other Lacey Act News, a 75 year old lepidopterist in New York pleaded guilty to smuggling rare birdwing butterflies.

Treasury's Office of Foreign Asset Control issued notices renaming and modifying sanctions in Sudan, updating Venezuela FAQs, and making grammatical changes to update existing sanctions.

Citing the Chinese government's broad authority to access and control the "vast amounts of data" generated by by chinese vehicles and components, the US Department of Commerce is preparing rules to bar trading with Chinese Automakers and suppliers of advanced componentry.  Commerce has issued an advance notice of proposed rulemaking (ANPRM) seeking public comment to inform the potential development of regulations to secure and safeguard the Information and Communications Technology and Services (ICTS) supply chain for connected vehicles (CVs).  

The U.S. Department of State’s Bureau of Political-Military Affairs “the Bureau” is accepting membership applications for the Defense Trade Advisory Group (DTAG). The Bureau is interested in applications from subject matter experts from the United States defense industry, relevant trade and labor associations, and academic and foundation personnel.

Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the United Kingdom, has sanctioned the Deputy Commander of Iran’s Islamic Revolutionary Guard Corps-Qods Force, a Yemeni militant, and two cargo vessels carrying Iranian petroleum.

Sen. Josh Hawley has introduced legislation to increase the tariffs on Chinese Electric Vechicles form the current 25 percent to 125 percent. This would be the first time that congress has actually set tariff rates since the Tariff Act of 1930, cosponsored by Rep. Willis Hawley of Oregon.

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. 

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.

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.

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