The United Kingdom on Feb. 10 updated its guidance on Iranian trade sanctions and its requirements for exporting certain controlled nuclear items on the U.K.'s “Trigger List.” The notices now include links to further information on exporting nuclear and dual-use goods and services through the Iran procurement channel.
Iran Export Controls
Certain items on the Commerce Control List require a license from BIS to export them to Iran. The Iranian Transactions Sanctions Regulations (ITSR) (31 CFR Part 560) also prohibit the export and reexport of goods to Iran subject to EAR.
The Treasury’s Office of Foreign Assets Control sanctioned four international petrochemical and petroleum companies that have transferred hundreds of millions of dollars worth of exports from the National Iranian Oil Company, Treasury said in a Jan. 23 press release. The NIOC is “instrumental” in Iran’s petroleum industry and helps finance Iran’s Islamic Revolutionary Guard Corps-Qods Force, the agency said. OFAC sanctioned Hong Kong-based broker Triliance Petrochemical Co., Hong Kong-based Sage Energy HK, Shanghai-based Peakview Industry Co. and Dubai-based Beneathco DMCC.
Export Compliance Daily is providing readers with some of the top stories for Jan. 6-10 in case you missed them.
President Donald Trump issued an executive order expanding U.S. sanctions authority against Iran and the Treasury Department announced a series of new Iran sanctions, including measures against senior Iranian officials, metal companies and a vessel. The executive order grants the U.S. the authority to impose a series of new primary and secondary sanctions against people and companies involved with Iran’s construction, mining, manufacturing and textiles sectors, Treasury Secretary Steven Mnuchin said during a Jan. 10 press conference. While the executive order only mentioned those four sectors, additional Iranian sectors may be sanctioned, Mnuchin said.
China’s Foreign Ministry criticized a report released this week by the Congressional-Executive Commission on China that called for U.S. sanctions on Chinese officials, saying the commission has no “objectivity or credibility whatsoever.” The report, issued Jan. 8, also called for greater U.S. export controls on surveillance technologies being sent to China and urged the Trump administration to place more Chinese companies and agencies on the Commerce Department’s Entity List due to their involvement in human rights violations (see 2001080039).
More than half of the sanctions-related enforcement actions issued by the Treasury Department in 2019 involved supply chain violations, signaling that supply chain compliance is one of the most important factors in avoiding violations, according to a December report released by Kharon, a sanctions advisory firm. The penalties are mostly due to deficiencies in three main areas of supply chain compliance, Kharon said: companies that operated in “heightened-risk jurisdictions,” companies that operated “existing and newly acquired” foreign subsidiaries, and companies that showed deficiencies while monitoring actors in its supply chain.
The State Department issued a Dec. 16 sanctions advisory about exports of graphite electrodes and needle coke to Iran, saying those materials subject exporters to “significant sanctions risk.” Both materials are “essential” to Iran’s steel industry, the State Department said, which is sanctioned by the U.S. Sanctions extend to producers and exporters of the materials along with “port operators, shippers, shipping companies, and vessel operators and owners,” who may be subject to blocking sanctions, even if the intended end-user is not in Iran’s steel sector.
Export Compliance Daily is providing readers with some of the top stories for Dec. 9-13 in case you missed them.
About a year into the Trump administration's maximum pressure sanctions campaign on Iran, the effort has done nothing to bring Iran to the negotiating table, panelists said during a Dec. 12 Atlantic Council event. U.S. sanctions have instead emboldened a more aggressive Iran, panelists said, which is growing increasingly frustrated with its unwilling European trade partners and will likely continue breaching the terms of the Joint Comprehensive Plan of Action.
The Treasury’s Office of Foreign Assets Control issued two Iran-related frequently asked questions to address its Dec. 11 designations of the Islamic Republic of Iran Shipping Lines (IRISL) and E-Sail Shipping Limited (see 1912110024). In FAQ 810, OFAC said the two entities are also subject to prohibitions under the Weapons of Mass Destruction Proliferators Sanctions Regulations due to their designation by the State Department. In FAQ 811, OFAC specified that license exceptions for exports of food, medicine and other humanitarian items generally do not apply to parties sanctioned for weapons proliferation activities. U.S. exporters will not be able to ship “agricultural commodities, food, medicine, or medical devices” to IRISL and E-Sail, OFAC said. Exporters who ship those items “risk exposure to sanctions under additional authorities.” To avoid risks, U.S. exporters should make sure sales of those goods are completed no later than June 8, 2020, when the designations take effect, OFAC said.