Iran Export Controls

A former State Department official who advised on sanctions and money laundering, who also is a co-founder of Sayari Labs, a financial intelligence and commercial data provider, said that Hudson Institute will produce a paper on creating a broad sanctions program for China, complete with the kind of language that would allow it to be executive-order ready.

The U.S. this week sanctioned 10 companies and four people with ties to Iran’s unmanned drone program, including Hossein Hatefi Ardakani, the Iranian-based leader of the network who helped illegally procure hundreds of thousands of dollars worth of U.S. and foreign-made components to Iran. Along with the new sanctions, DOJ charged Ardakani and his accomplice, China-based Gary Lam, for violating U.S. export controls.

The Bureau of Industry and Security is working more closely with the Office of Foreign Assets Control on enforcement issues, which could allow the two agencies to better align the BIS Entity List and OFAC’s Specially Designated Nationals List, a BIS official said this week.

Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.

The EU released Oct. 20 its annual report on the implementation of the bloc's strategy targeting weapons of mass destruction proliferation. The report breaks down the state of issues regarding nuclear, chemical and biological issues, along with the current export control and sanctions regimes geared towards addressing these problems.

Multinational companies with operations in China are becoming increasingly concerned about facing retaliatory measures from Beijing for complying with Western sanctions, said Erika Trujillo, co-founder of SEIA, a compliance risk management firm. She noted that some businesses have begun to split their trade compliance efforts between a Western-focused team and a Chinese team to protect their Chinese employees and operations from potential penalties.

U.N. sanctions on Iranian missile-related activities expired Oct. 18, as part of a sunset clause included in the 2015 Iran nuclear deal, which had lifted certain sanctions against Iran in return for the country placing limits on its nuclear program. The sunset in the nuclear deal “was based on the assumption that Iran would take the necessary steps towards restoring confidence in the exclusively peaceful nature of its nuclear program,” the State Department said. “This has not happened.”

The U.S. this week sanctioned 11 people, eight entities and one vessel with ties to Iran’s ballistic missile and drone programs. The Treasury, Commerce and State departments, along with DOJ, also published a new advisory to alert global companies about Iran’s ballistic missile procurement activities.

Export Compliance Daily is providing readers with the top stories from last week in case you missed them. You can find any article by searching for the title or by clicking on the hyperlinked reference number.

The Office of Foreign Assets Control this week sanctioned seven people and four entities in China, Iran, Russia and Turkey for their involvement with Iran’s drone development and production. The agency also updated the existing entry for U.S.-sanctioned Iran Aircraft Manufacturing Industrial Company (HESA) to add a new alias, saying that the company since last year has used the name Shahin Co. in contracts with overseas suppliers to evade U.S. sanctions and export controls.