The House Foreign Affairs Committee on Feb. 6 approved a bill that would designate the Houthis as a Foreign Terrorist Organization following the Yemen-based group’s recent attacks on commercial ships in the Red Sea.
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 U.S. charged four Chinese nationals this week for their parts in a yearslong conspiracy to violate export controls by smuggling electronic parts through China and to Iran.
The Bureau of Industry and Security will likely issue more penalty announcements this year for export control violations, a former senior BIS enforcement official said, suggesting the current state of enforcement is unprecedented.
Electronics distribution company Broad Tech System and its president and owner, Tao Jiang of Riverside, California, pleaded guilty Jan. 11 to participating in a conspiracy to illegally ship chemicals made or distributed by a Rhode Island-based company to a Chinese firm with ties to the Chinese military, the U.S. Attorney's Office for the District of Rhode Island announced. Jiang and Broad Tech admitted to violating the Export Control Act and conspiring to commit money laundering.
Behrouz Mokhtari of McLean, Virginia, and Tehran pleaded guilty Jan. 9 to two conspiracies to violate U.S. sanctions on Iran "by engaging in business activities on behalf of Iranian entities" without getting a license from the Treasury Department's Office of Foreign Assets Control, DOJ announced Jan. 9. Mokhtari will forfeit money, property and assets obtained from the schemes, including a Campbell, California, home, and a money judgment of over $2.8 million, DOJ said. The defendant faces a maximum of five years in prison for each of the two conspiracy counts.
The Bureau of Industry and Security this week expanded its export controls against Russia and Belarus to cover a broader range of items and Harmonized System codes, including more industrial materials and aircraft parts. The agency also added new controls to better restrict exports used in Iran’s drone production, revised the de minimis treatment for certain military and spacecraft-related items, added a new license requirement exclusion and more.
Jalal Hajavi of Virginia was sentenced to two years in prison and three years of supervised release after he illegally exported heavy equipment from the U.S. to Iran, DOJ announced this week. Hajavi also misled a U.S. freight forwarder about the “ultimate destination” of the shipment, DOJ said, which caused the forwarder to file false export information to the Commerce Department.
The State Department gathered an undisclosed “group of countries” last week to “strategize” on ways to curb the supply of parts to Iranian drones, a department official said Jan. 17.
The U.S. fined German software company SAP SE more than $200 million for violating the Foreign Corrupt Practices Act, saying it bribed government officials in South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia and Azerbaijan to secure business contracts. The company agreed to a nearly $100 million settlement with the SEC and faces a $118.8 million criminal penalty, along with a forfeiture, as part of a deferred prosecution agreement with DOJ.
The Commerce Department’s export enforcement actions in 2023 resulted in the “highest number ever” of convictions, temporary denial orders and post-conviction denial orders, the Bureau of Industry and Security wrote in a year-end review. It also said it worked with foreign governments to complete over 1,500 end-use checks, “our most ever in a single year,” and added more than 465 parties from China, Iran, Russia and elsewhere to the Entity List.